Privacy Policy
Cyber8Ball — Privacy Policy
Privacy Policy of Cyber8Ball
ASTRAEUS HK LIMITED. (referred to as “we” and “our” and “us”) , the operator of Cyber8Ball, with the headquarter in obeys relevant laws and regulations, and respects your right to maintain the private information through your use of the Cyber8Ball app (“App”).
Only with your prior consent to certain reasonable extent, we collect user feedback, app date, and your personal data while providing our services to improve user experience.
This Privacy Policy explains how we and our related entities will collect your personal data and protect your privacy. This policy was written in English. To the extent a translated version conflicts with the English version, the English version prevails.
Unless indicated otherwise, this Privacy Policy does not apply to any third party products or services or the practices of companies that we do not own or control, including other companies you might interact with on or through our services.
Cyber8Ball is a global Web 3.0 related business, we will always act in accordance with the Hong Kong’s Personal Data Protection Act and various jurisdiction-specific privacy provisions outlined in this Privacy Policy.
Definition of Personal Data under this Policy
Personal data, or Privacy, means data about an individual who can be identified from that data, or from that data and other information to which the organisation has or is likely to have access. All personal data received in connection with our business is subject to strict rules of confidentiality. Usually, personal data include your name, username, password, IP address, unique device identifiers, gender, signature, address, telephone number, email, date of birth, bank account and digital wallet details, billing and credit or debit card details, visual asset amount, photos and videos of you, hobbies and education background, other identification credentials and biographical details, and commentary or opinions about you.
We collect information about your location and physical movements so that the App to function properly and monitor and verify forms of eligible movement. You may turn location monitoring on and off from time to time using the settings of your operating system of your mobile device but, if you disable this functionality, we will not be able to collect information relating to your GPS/Cell-ID location which will prevent tracking and/or conversion of your movement into NFTs.
Personal data that we may collect from you
We may collect the following types of personal data:
1.information that you give us through your dealings with us;
2.information that we may collect from you; and
3.information that we may receive from you from other third party sources.
By agreeing to this Privacy Policy, you agree on the fact that you are aware that we are collecting your personal data and disclosing it as required by us and in accordance with the Singapore Personal Data Protection Act and any applicable privacy principles.
How personal data being collected
“Personal data” is data that identifies, describes, used to or may be used to contact, or could reasonably be linked directly or indirectly to you. You may decline to provide some of the personal data defined above. Please note that however, some of our services require some personal data to operate, so if you deny to provide the personal data necessary to operate and provide you with a particular service or feature of that service, you may not be able to use that service or feature.
- Information that you share with us
We may collect your personal data directly from your sign-up page, our contact with you or other possible source when you are using the APP. This may include:
- you completing forms or parts of our website, social media (web or internet based or mobile telephonic devices or medium such as Facebook, Twitter, Instagram, LinkedIn, Whatsapp and so forth, which enable the creation and exchange of user generated content, hereafter referred to as Social Media),
- App and/or other software and/or mobile applications, providing to us with your consent to access personal data such as photographs, videos or photo albums, providing to us with your consent to access the microphone and/or camera on your device, or
- you contacting us via the email, telephone, through social media and other similar functions either directly through our website or the App or through third party host websites, in person, through various marketing channels or competitions either directly through our website or the App or through third party host websites, and surveys.
We assume that the aforementioned information would be true, accurate and up to date.
- Information that we collect about you
Our App, website, Social Media and/or other software and/or applications may automatically collect the following information about you when you visit or otherwise use them:
- information or details regarding digital assets held;
- particulars of digital wallet addresses (including transactions performed by said digital wallet addresses), public cryptographic key relating to digital wallet addresses on distributed ledger networks and/or similar information;
- technical information including but not limited to the internet protocol address used to connect your device to the internet, the internet browser and version that you are using when accessing our App, website, Social Media or other software and/or mobile applications, additional plug-ins, cookies and your device’s operating system and platform; and
- information about the time and date you accessed our App, website, Social Media, or other software and/or mobile applications, and what you accessed on our App, website, Social Media, or other software and/or mobile applications. This includes links that you clicked on, what content you accessed, how long you accessed that content for, whether you downloaded any content, whether supplied by us or downloaded from a third party, and how you navigated to and from our App, website, Social Media or other software and/or mobile applications to other sites, apps or other pages hosted by us.
- Sensitive information
In the course of collecting your personal data, we may collect sensitive information about you. Sensitive information includes:
- information or an opinion about your racial or ethnic origin; or political opinions; or religious beliefs or affiliations; or philosophical beliefs; or membership of a political, professional or trade association; or sexual orientation or practices; or criminal record that is also personal data; or
- health information about an individual; or genetic information about an individual that is not otherwise health information; or biometric information that is to be used for the purpose of automated biometric verification or biometric identification.
With respect to any sensitive information, we will only collect it in accordance with Personal Data (Privacy) Ordinance. We will only collect this information with your consent and for reasons that are reasonably necessary or otherwise related to the provision of our services. Where you agree that we could collect your sensitive information, you also consent that we may use that sensitive information for the purpose/s for which it was collected, including disclosure to third parties.
Personal data and the Blockchain
Blockchain technology, also known as distributed ledger technology (DLT), is at the core of our business. Blockchains are decentralised and made up of digitally recorded data in a chain of packages called “blocks”. The manner in which these blocks are linked is chronological, meaning that the data is very difficult to alter once recorded. Since the ledger may be distributed all over the world (across several “nodes” which usually replicate the ledger) this means there is no single person making decisions or otherwise administering the system (such as an operator of a cloud computing system), and that there is no centralised place where it is located either. Accordingly, by design, a blockchain’s data cannot be changed or deleted and is said to be “immutable”. This may affect your ability to exercise your rights such as your right to erasure (“right to be forgotten”), or your rights to object or restrict processing of your personal data. Data on the blockchain cannot be erased and cannot be changed. Although smart contracts may be used to revoke certain access rights, and some content may be made invisible to others, it is not deleted.
In certain circumstances, in order to comply with our contractual obligations to you (such as delivery of tokens or provision of other services) it will be necessary to collect certain personal data, such as your wallet address, onto the blockchain; this is done through a smart contract and requires you to execute such transactions using your wallet’s private key.
The ultimate decisions to (a) transact on the blockchain using your wallet address, as well as (b) share the public key relating to your wallet address with anyone (including us) rests with you. IF YOU WANT TO ENSURE YOUR PRIVACY RIGHTS ARE NOT AFFECTED IN ANY WAY, YOU SHOULD NOT TRANSACT ON BLOCKCHAINS AS CERTAIN RIGHTS MAY NOT BE FULLY AVAILABLE OR EXERCISABLE BY YOU OR US DUE TO THE TECHNOLOGICAL INFRASTRUCTURE OF THE BLOCKCHAIN. IN PARTICULAR THE BLOCKCHAIN IS AVAILABLE TO THE PUBLIC AND ANY PERSONAL DATA SHARED ON THE BLOCKCHAIN WILL BECOME PUBLICLY AVAILABLE.
How we use your personal data
You consent to our collection of your personal data and disclosing it to third parties, including your related entities where necessary and for the purposes for which it was collected. This may include:
- providing our services relating to the game and metaverse ecosystem operated by us;
- developing and providing products or services (whether made available by us or through us) or your participation in interactive features of our services;
- acting as intermediaries through any blockchain, network or platform;
- recording and/or encryption on any blockchain, network or platform;
- investigating and/or preventing suspected fraud or other criminal activities or misuse of our services, including the use of your location and movement data connecting with our anti-cheating system;
- where we collect or disclose information that is or relates to the internet protocol address used to connect your device to the internet, for the purpose of fraud detection and management of the integrity of Cyber8Ball and other services. This may include detecting when users are cheating on the Cyber8Ball system, and for handling, freezing accounts suspected as stolen ones. This information helps us verify whether the account or associated assets belong to a particular user;
- where information relates to system version information of your device, or the model of your device, for the purpose of our compatibility assessments with our software versions and other services;
- comprising all users or users meeting particular criteria;
- operating the App’s Marketplace;
- investigating disputes between users;
- using your personal data to provide you with information that you have requested from us, although we do not create a link between your user ID and your user email;
- communicate with you, including to inform you of updates to the App, website, our Terms of Use and/or the Privacy Policy;
- authenticating your financial account information or processing the transfer of digital assets;
- authenticating your credit or debit card information;
- using your personal data for marketing purposes to provide or offer services to you. This includes, but is not limited to, keeping you up to date with our latest news, events, special offers and promotion of our brand or other similar products that we think that you may be interested in. This includes both our direct marketing to you or another third party whom you have authorized us to disclose your personal data to;
- notifying you about any changes to our products, website, App and/or other software and/or mobile applications, brand or services offered;
- for the purposes of product improvement and customization, website or App improvement, personalization and other general services, seeking your feedback;
- for consumer engagement and/or service purposes, including but not limited to identifying the effectiveness of advertising, allowing you to participate on website viral features such as sharing website content and other community features (for example, whatsapp, twitter, facebook, blogs);
- for other general services such as website/software security, maintenance, identification of fraud or errors, internal accounting and administration, and for any other purpose that we are required or permitted to do by law;
- managing our relationships with you and other users;
- enforcing obligations owed to us, protecting our rights or property, and protecting against legal liability; and/or
- seeking professional advice, including legal or tax advice.
Certain of your personal data may be shared with other players of the App as part of the normal operation of our services. Also, we may expand or withdraw our business which may involve the transfer of certain of our divisions or assets to other parties, and the data we store and use, where relevant, may be transferred to such third parties. We may, from time to time, transfer the data we store and use to locations outside Singapore, some of which may have different data protection laws to Hong Kong. For oversea users or other requirements stipulated by local laws and regulation, we might utilize overseas IT services (including software, platforms and infrastructure), such as data storage facilities or other IT infrastructure. Thus, we may own or control such overseas infrastructure or we may have entered into contractual arrangements with third party service providers to assist us with providing our services to you.
As we utilize cross-border services and platforms which can be accessed from various countries via an internet connection, it is not always practicable to know where your information may be held.
Disclosure obligations stipulated by Laws and Regulations
We may be required to disclose your personal data for the purposes for which it was collected and also subject to our legal obligations:
- as stipulated by laws and regulations;
- to any person where necessary in connection with our provision of services; and
- on a confidential basis to the external service providers and advisors.
You consent to our disclosure of your personal data to any of our business partners, suppliers, subcontractors or the like, advertisers and other advertising networks, analytics and search engine providers and other third parties provided the disclosure of your personal data is for the purpose or ancillary to the services that we or these third parties offer you and for the purposes the information was originally collected.
We may share your information with other third party business partners for their own marketing purposes. These third parties include online advertisers or ad tech companies, who may provide you with targeted advertising and marketing communications, where permitted under law.
You also understand that we are authorized to disclose your personal data to third parties if we buy or sell any business or assets, including our business, if we are under a duty to disclose your information, or if the disclosure of your personal data is necessary for us to conduct an investigation into any unlawful activity that we know or suspect has or may be engaged in.
You consent to the disclosure of all information necessary for us to comply with any relevant reporting obligations (if any) pursuant to the Drug Trafficking (Recovery of Proceeds) Ordinance, Organized and Serious Crimes Ordinance, United Nations (Anti-Terrorism Measures) Ordinance, Anti-Money Laundering and Counter-Terrorist Financing Ordinance and other relevant laws and regulations.
We wish to emphasise that we do not sell personal data to any third parties and we shall remain fully compliant of any duty or obligation of confidentiality imposed on us under the applicable agreement(s) and/or terms and conditions that govern our relationship with you or our customer or any applicable law.
We will take all reasonable measures to ensure that any recipient of your personal data does not willingly or knowingly breach the Singapore laws in relation to your personal data.
How we store your personal data
Cyber8Ball takes commercially reasonable technical and physical security measures to protect your information from loss, misuse, leak, unauthorized access, alteration, and destruction.
When your bank, financial account or digital wallet information is being transmitted to our services or through our services, it will be protected by cryptographic protocols. We do not ourselves store your account information, and we do not have direct control over or responsibility for your credit or debit card account information. We may use third party payment processors that are the controllers of your information. The services provided by the third parties that receive your information require them to keep such information secure and confidential. However, we cannot guarantee that transmissions of your information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by us or our third party service providers. Except to the extent that liability cannot be excluded or limited due to applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third party access, or other causes beyond our control.
We will delete your information after a reasonable time. You may be required to re-enter your personal data if it has been deleted.
You agree and acknowledge that your personal data may be stored at or transferred within Hong Kong or a destination outside of Hong Kong. This will allow our staff outside of Hong Kong (whether employed by us or by a third party engaged by us or otherwise authorized under this Privacy Policy to access your personal data) to process your information for the purposes of providing you with our services.
We will take all reasonable steps and precautions to ensure that any transmission of your personal data via the internet is secure. However, we cannot guarantee the security of any data transmitted to our website and you agree and acknowledge that any such transmissions are at your own risk.
We take reasonable steps to protect your personal data, which include storing any information on a secure server, or kept in a physical storage, and employing strict procedures and security features to protect your personal data from any unauthorized recipients and to prevent unauthorized access to the same.
Collections of your information using cookies and other tracking technologies
Cookies are small pieces of data sent from a website and stored in your web browser. Our website and/or App and/or other mobile applications use Cookies that allow our website and/or App to remember who you are and to obtain information from you, so that we will be able to deliver you a better and more customized service..
As a result of our website and/or App and/or other mobile applications’ use of cookies, we may collect information such as your IP address, online activity and your web browser details. Information that we will not collect or store includes your passwords or other sensitive information.
We use both persistent cookies, which could remain on your device until their expiration, and session cookies, which are temporary files removed from your device once your browser is closed. The types of cookies we may use include analytical and tracking cookies, which allow us to recognize and count the number of visitors and analyze use of the services, as well as to verify transactions, and advertising and re-targeting cookies, so that we can generate appropriate advertising directed to you.If you enabled cookies when accessing our website and/or App and/or other mobile applications, we will take this as consent to our use of cookies and other technologies mentioned in our Privacy Policy. Please note that you should also refer to our website’s Terms of Use for further information on this issue.
Users’ rights
You have the right to request access to the personal data we hold about you by contacting us by emailing to contact@astraeus-inc.com
If we cannot provide you with access, we will write to you and provide you with the reasons why we are unable to provide you with access. If any personal data that we hold about you is inaccurate, incomplete or not up to date, you may inform us to correct the information at the above address.
You have the right to request that we do not disclose your personal data (for example, for marketing purposes). You can exercise your rights by unchecking the relevant check boxes on our website and/or App and/or other mobile applications when you provide us with your personal data, or by writing to us at the above address. You may also deny receiving any further correspondence from us by writing to us at the above address or emailing us at the above email address.
Queries, Access/Correction Requests and Withdrawal of Consent
If you have queries about our data protection processes and practices, wish to request access to and/or make corrections to your personal data in our possession or under our control; or wish to withdraw your consent to our collection, use or disclosure of your personal data, please submit a written request (with supporting documents, (if any) to our Data Protection Officer at: contact@astraeus-inc.com. Our Data Protection Officer shall respond to you within 30 days of your submission. Please note that if you withdraw your consent to any or all use or disclosure of your personal data, depending on the nature of your request, we may not be in a position to continue to provide our services or products to you or administer any contractual relationship in place. Such withdrawal may also result in the termination of any agreement you may have with us. Our legal rights and remedies are expressly reserved in such event.
We may charge you a fee for processing your request for access. Such a fee depends on the nature and complexity of your access request. Information on the processing fee will be made available to you.
Governing Law and Jurisdiction
This Privacy Policy and your use of the website shall be governed and construed in accordance with the laws of Hong Kong.
All disputes arising out of or in connection with this Privacy Policy (including without limitation the enforceability of this section or any question regarding its existence, validity or termination, your access or use of the services shall be referred to and finally resolved by arbitration administered by the Hong Kong International Arbitration Centre (HKIAC) in accordance with the Arbitration Rules of the Hong Kong International Arbitration Centre (HKIAC Rules) for the time being in force, which rules are deemed to be incorporated by reference in this section. The seat of the arbitration shall be Hong Kong. The Tribunal shall consist of 1 arbitrator. The language of the arbitration shall be English. The award of the arbitrator will be final and binding, and any judgment on the award rendered by the arbitrator may be entered in any court of competent jurisdiction. Each party irrevocably submits to the jurisdiction and venue of such tribunal. Further, each party will cover its own fees and costs associated with the arbitration proceedings.
Jurisdiction-specific provisions — Residents of the EEA and the United Kingdom
Through our website, Social Media, App and/or other software and/or mobile applications, we provide services to users throughout the world. We are primarily bound by the Hong Kong’s Personal Data Protection Act and the Hong Kong privacy principles and we will manage your personal data pursuant to these laws. In addition, as we process personal data of data subjects inside the European Economic Area (“EEA”) we are also bound by Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”).
The purpose of the following data protection information is to provide you with an understandable, transparent and concise explanation of how we intend to process your personal data in accordance with Articles 13 and 14 of the GDPR. However, should you require further explanations relating to our data protection or wish to exercise any of your rights, please do not hesitate to contact us at contact@astraeus-inc.com.
We recognize the below rights which you enjoy under the applicable data protection law with respect to your personal data:
- Right to be informed: You have the right to be informed about the collection and use of your personal data, and this right is set out in this Privacy Policy.
- Right of access: You may request information from us at any time as to whether we have stored your personal data and which personal data it has stored. We are required to provide this information to you for free.
- Right to rectification: If your personal data stored by us is inaccurate or incomplete, you have the right to demand us to correct the error.
- Right to erasure: You have the right to demand that we erase your personal data if and to the extent that the data is no longer needed for the purposes for which it was collected or if the data is processed based on your consent, and you have opted to revoke your consent. Then we must cease processing your personal data and remove that data from our IT systems and databases. You do not have a right to erasure if the data may not be deleted due to a statutory obligation or must be processed due to a statutory obligation; or the processing of data is necessary for the establishment, exercise or defence of any legal claims.
- Right to restriction of processing: You have the right to demand that we restrict the processing of your personal data.
- Right to object to processing: If your data is processed by us on the basis of Article 6(1)(f) GDPR, you may object at any time to processing by us. You may assert any and all of the rights of data subjects described above against us by addressing your specific requests by contacting us via contact@astraeus-inc.com.
- Right to lodge a complaint with a data protection supervisory authority: Pursuant to Article 77 GDPR, you have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data infringes data protection law.
Retention of personal data
Your personal data is retained as long as the purpose for which it was collected remains and until it is no longer necessary for any legal or business purposes. This enables us to comply with legal and regulatory requirements or use it where we need to for our legitimate purposes, such as transfers of digital assets, and dealing with any disputes or concerns that may arise.
We may need to retain information for a longer period where we need the information to comply with regulatory or legal requirements or where we may need it for our legitimate purposes (e.g. to help us respond to queries or complaints, fighting fraud and financial crime, responding to requests from regulators etc).
When we no longer need to use personal data, we will remove it from our systems and records and/or take steps to anonymise it so that you can no longer be identified from it.
Complaints
If you are concerned about a possible interference with your privacy or about the potential misuse of your personal data, please contact us at the above email address.
We take all complaints very seriously and we handle complaints in a timely, effective, fair and consistent manner. If you are not satisfied with our response, you have the right to refer your complaint to the our Hong Kong headquarter (12/F ZJ 300,300 LOCKHART RD WAN CHAI HONG KONG)
Privacy Policy updates
This Privacy Policy was last updated in July 2023. We reserve the right to alter or update the Privacy Policy from time to time. We encourage you to regularly review this Privacy Policy to make sure you are aware of any changes and how your information may be used.