LAST UPDATED:  May 2024

THE SANDBOX FOUNDATION

 PRIVACY POLICY 

The Sandbox Foundation (“we,” or “us”) wants you to be familiar with how we collect, use and disclose information.  This Privacy Policy describes our practices in connection with information that we collect through: 

  • Websites operated by us from which you are accessing this Privacy Policy (the “Websites”); 
  • HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you; and

Collectively, we refer to these interactions as the “Services.”  

PERSONAL INFORMATION

Personal Information” is information that identifies you as an individual or relates to an identifiable individual.  The Services could collect Personal Information, including:

  • Name
  • Email address
  • Postal address 
  • Username and password
  • Crypto wallet address, including related data to detect cryptocurrency and NFT holdings
  • Social media handle
  • IP address
  • Government-issued ID, for KYC purposes.

Collection of Personal Information 

With your consent, we and our service providers collect Personal Information in a variety of ways, including:  

  • Through the Services.  

We collect Personal Information through the Services, for example, when you register an account to access the Services, connect your wallet, complete a survey, contact customer support or take part in governance votes. 

  • From Other Sources.  
  • We receive your Personal Information from other sources, for example, crypto wallet providers.

We need to collect Personal Information in order to provide the requested Services to you.  If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority, consent to do so and hereby allow us to use the information in accordance with this Privacy Policy. 

Use of Personal Information 

Further to your consent, we and our service providers use Personal Information for the following purposes: 

Providing the functionality of the Services and fulfilling your requests. 

  • To provide the Services’ functionality to you, such as arranging access to your registered account, voting, and providing you with related benefits, special promotions, or customer service.
  • To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request information about our Services.
  • To send administrative information to you, such as changes to our terms, conditions, and policies. 

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation. 

Providing you with our marketing materials and facilitating social sharing.

  • To send you marketing related emails, with information about our services, new products and other news about our company. 
  • To facilitate social sharing functionality that you choose to use.

We will engage in this activity with your prior consent,  where we have a legitimate interest.

  • Analyzing Personal Information for business reporting and providing personalized services. 
  • To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services. 
  • To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
  • To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

We will provide personalized services based on our legitimate interests, and with your prior consent to the extent required by applicable law. 

  • Aggregating and/or anonymizing Personal Information.
  • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. 

  • Accomplishing our business purposes. 
  • For data analysis, for example, to improve the efficiency and quality of our Services; 
  • Debug, identify and repair errors that impair the intended functionality of our Services.
  • For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements; 
  • For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft; 
  • For developing new products and services; 
  • For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures; 
  • For identifying usage trends, for example, understanding which parts of our Services are of most interest to users; 
  • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and 
  • For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.  

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.

Other Partners  

In order to provide you with an optimal experience on our site, and provide you with the best services, we also use the services of third party partners. It is specified that The Sandbox Foundation is not affiliated with third-party companies and cannot be held responsible for them. Therefore, we invite you to consult the data protection policies used by our partners: 

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable law and regulations.
  • This may include laws outside your country of residence. 
  • To cooperate with public and government authorities.
  • To respond to a request or to provide information we believe is necessary or appropriate.
  • These can include authorities outside your country of residence.
  • To cooperate with law enforcement.
  • For example, when we respond to law enforcement requests and orders or provide information we believe is important.
  • For other legal reasons. 
  • To enforce our terms and conditions; and
  • To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others. 
  • In connection with a sale or business transaction.
  • We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). 

OTHER INFORMATION

Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. Further to your consent, Services could collect Other Information such as:  Browser and device information, Information collected through cookies, pixel tags and other technologies, Demographic information and other information provided by you that does not reveal your specific identity, Information that has been aggregated in a manner such that it no longer reveals your specific identity.

  • Your browser or device.  

Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using.  We use this information to ensure that the Services function properly.  

  • Cookies. 

Cookies are pieces of information stored directly on the computer that you are using.  Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, mouse clicks, page scrolls, keystrokes, and other traffic data.  Upon your consent, we and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience.  We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. 

  • Management and Deletion of Cookies

The management of cookies depends entirely on your choice of settings on your terminal. You can use the Cookie Notice tool, available in the settings of your browser software, to choose to accept or refuse the recording of non-essential cookies on your terminal at any time.  The configuration of each navigation software is different. It is generally described in the help menu of your navigation software. 

We therefore invite you to read it to find out how to modify your settings depending on your browser:

You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.  You also may not receive advertising or other offers from us that are relevant to your interests and needs. 

Pixel tags and other similar technologies.  

  • Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.  
  • Analytics. Upon receiving your consent, we could use third party analytics service providers, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  These analytics services may also collect information regarding the use of other websites, apps and online resources.  You can learn about Mixpanel’s practices by going to https://mixpanel.com/legal/privacy-policy/. 

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes.  If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by clicking the unsubscribe link in such email.

How you can access, change, or delete your Personal Information  

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below.  We will respond to your request consistent with applicable law.  In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database.  For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable.  

Please note that we may need to retain certain information for recordkeeping purposes.  

RETENTION PERIOD

We retain Personal Information for as long as needed or legally permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. 

The criteria used to determine our retention periods include:  

  • The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services); 
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or 
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).  

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18. 

JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information could be transferred to countries outside of your country of residence, including the United States (pursuant to Adequacy Decisions),  which may have data protection rules that are different from those of your country.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

ADDITIONAL INFORMATION REGARDING THE EEA AND THE UK: Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these “specified countries” is available at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. The UK recognizes the EEA and the specified countries as providing an adequate level of data protection according to UK standards.  For transfers from the EEA or the UK to countries not considered adequate by the European Commission or the UK government (as applicable), we have put in place adequate measures, such as standard contractual clauses adopted by the relevant authority to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contact Us” section below.

You may lodge a complaint with a data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of European Economic Area (EEA) data protection authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.  Information regarding the UK data protection authority is available here: 

ADDITIONAL INFORMATION REGARDING CALIFORNIA 

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Personal Information that we collect, use, and disclose about California residents. This section does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role with us. 

Collection and Disclosure of Personal Information

The following chart details which categories of Personal Information about California residents we plan to collect, as well as which categories of Personal Information we have collected and disclosed for our operational business purposes in the preceding 12 months. 

Categories of Personal Information

Disclosed to Which Categories of Third Parties for Operational Business Purposes

Identifiers, such as username, contact information, government-issued ID, IP address and other online identifiers

Affiliates; service providers; business partners; joint marketing partners; contest sponsors; legal authorities

Personal information as defined in the California customer records law, such as name, contact information and government-issued ID

Affiliates; service providers; business partners; joint marketing partners; contest sponsors; legal authorities

Commercial Information, such as transaction information and purchase history

Affiliates; service providers; business partners; joint marketing partners; contest sponsors; legal authorities

Internet or network activity information, such as interactions with our online properties 

Affiliates; service providers; business partners; joint marketing partners; contest sponsors; legal authorities

Geolocation Data, such as approximate location derived from IP address

Affiliates; service providers; business partners; joint marketing partners; contest sponsors; legal authorities

Audio/Video Data. Audio, electronic, and similar information

Affiliates; service providers; business partners; joint marketing partners; contest sponsors; legal authorities

We do not “sell” and have not “sold” Personal Information for purposes of the CCPA in the last 12 months. 

Sources of Personal Information 

As described above, we collect these categories of Personal Information from you and from crypto wallet providers, when they share the information with us.

Use of Personal Information

As described above, we use these categories of Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including using Personal Information to:

  • Fulfill your requests and respond to your inquiries;  
  • Develop, improve, repair, provide and maintain our products and services;
  • Personalize, advertise, and market our products and services;
  • Allow you to participate in raffles, sweepstakes, contests or other promotions; 
  • Conduct research, analytics, data analysis, data aggregation, and data anonymization; 
  • Maintain our property and our records, and undertake quality and safety assurance measures; 
  • Conduct risk and security control and monitoring, and detect and prevent fraud; 
  • Perform identity verification, accounting, audit, and other internal functions, such as internal investigations and record-keeping; 
  • Carry out corporate transactions, such as mergers, joint ventures or acquisitions; and
  • Comply with law, legal process, and internal policies, and exercise and defend legal claims.

Individual Rights and Requests

If you are a California resident, you may request that we:

  • Disclose to you the following information covering the 12 months preceding your request: some text
    • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
    • The specific pieces of Personal Information we collected about you;
    • The business or commercial purpose for collecting (if applicable) Personal Information about you; and
    • The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
  • Delete Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please contact us at privacy@sandboxdao.com.  We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request.  We may need to request additional Personal Information from you, such as email address or wallet address, in order to verify your identity (via email PIN confirmation) to protect against fraudulent requests.  If you make a deletion request, we may ask you to confirm your request before we delete your Personal Information. 

You have the right to be free from unlawful discriminatory treatment for exercising your rights under the CCPA.

Authorized Agents

If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above.  As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent, which may include: 

1. Proof of your registration with the California Secretary of State to conduct business in California;

2. Proof of a power of attorney from the resident pursuant to Probate Code sections 4121-4130;

3. Signed permission that the resident has authorized you to make a request on the resident’s behalf.   

If you are an authorized agent and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4121-4130, we may also require the resident to:

1. Verify the resident’s own identity directly with us; or

2. Directly confirm with us that the resident provided you permission to make the request.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the Services.  

CONTACTING US

The Sandbox Foundation, located at Harbour Place, 2nd Floor, 103 South Church Street, P.O. Box 472, George Town, Grand Cayman KY1-1106, Cayman Islands, is responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy. 

If you have any questions about this Privacy Policy, please contact us at [email protected] or The Sandbox Foundation, Harbour Place, 2nd Floor, 103 South Church Street, P.O. Box 472, George Town, Grand Cayman KY1-1106, Cayman Islands.