# WADE CLUB

## WADE CLUB Privacy Policy

Last Updated: \[Feb 7, 2024]

When you use our products and services, you are trusting us with your information. We acknowledge and understand that this is a big responsibility. We work hard to protect your information.

As used in this Terms, WADE CLUB (“Services”) refers to as the Services provided by CRIPCO PTE. Ltd. (the “Company” or “CRIPCO,” “we,” “our,” or “us”) and its affiliates to the extent these Terms relate to any matter involving (1) code base licensed by CRIPCO or any data collected by CRIPCO or (2) any waivers, disclaimers, limitations of liability, and indemnities for the benefit of WADE CLUB or CRIPCO under these Terms.

This Privacy Policy (collectively, the “Terms”) is intended to explain and help you understand what information we collect, why we collect, use, and share it when you use WADE CLUB website(s), our APIs, mobile app, and any other software, tools, features, or functionalities provided on or in connection with our Services, and how you can update, manage, export and delete your information; including without limitation to using our Services to view, explore, and create NFTs and use our tools, at your own discretion, to connect directly with others to purchase, sell, or transfer NFTs on public blockchains or otherwise interact with us.

These Terms apply when you access or use the Services, or otherwise interact with us. Your access to the Services is governed by our Terms and Conditions and these Terms reflect how you can exercise your privacy rights. You may opt in whether to provide us with your personal data. If, however, you opt not to provide the required information to access and/or use the Services, or if you provide incomplete or incorrect information, you may not be able to use all or any portion of the Services.

If you choose to use our Services, you will be deemed to have acknowledged that you have read and understood these Terms in their entirety and have agreed CRIPCO’s collection, processing, usage, and storage of your personal information in accordance with the Terms. The information we collect shall only be used and processed for the purposes specified in this Policy. We will not use or share your personal data with anyone except as described in these Terms.

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1. #### Purpose and Collection of Personal Information

We may collect personal information about you from various sources, including the Services, when you call or email us or communicate with us through social media or our partners’ live chat functionalities, or when you participate in the events or other promotions. To the extent permitted by law, we may also collect information about you from our parent, affiliate or subsidiary companies, business partners and other third parties. Personal information collected by CRIPCO includes, but is not limited to, your identification, your blockchain-based wallet address (crypto wallet), NFTs or IP3 that your wallet holds within, your username, Twitter ID, Discord ID, and the country of residence (optional), and any relevant information about your use of the Services.

We may combine the information we collect with publicly available information and information we receive from our parent, affiliate or subsidiary companies, business partners and other third parties..

We may use that combined information to: set up and administer your account (where applicable); verify your identity; process your registration as a user; provide you with a log-in ID for the Services and maintain and manage your registration; provide you with customer service and respond to your queries, feedback, claims or disputes; enhance and personalize your experience with us; communicate with you about products, services and events that may be of interest to you (or for other promotional purposes); or make such disclosures as may be required for any of the above purposes or other purposes described in these Terms.

2. #### Provision of Personal Information to Third Parties

CRIPCO is based in Singapore, and it stores, processes, and transfers information in and to servers and databases located in the Amazon Web Services]. We may also store, process, and transfer information in and to servers in other countries, depending on the location of its affiliates and service providers.

We also may share personal information with our service providers who perform Services on our behalf under data processing or service agreements. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. CRIPCO reserves the right to update these Terms from time to time to reflect any new locations which CRIPCO’s business operations may expand to, which may include Europe, the Americas, and other Asia Pacific locations, and will not disclose any of your personal data without your consent unless required by applicable laws.

We also may disclose information about you (1) if we are required to do so by law or legal process (such as a court order), (2) in response to a request by law enforcement authorities, or (3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.

We also reserve the right to transfer personal information we have about you in the event we sell, merge or transfer all or a portion of our business or assets. Following such a sale, merger, or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.

If at any time you do not wish for your personal information to be transferred to a specific third party, you may contact our Data Protection Officer to refuse the transfer of your personal information. However, please note that if you refuse the transfer of your personal information, your use of the Services may be restricted.

3. #### Safety Measures

We will put in place reasonable security arrangements to protect against unauthorized or accidental disclosure, use, alteration, or destruction of the personal information you provide to us. If you have any questions about security relating to the Services, or if you wish to limit the processing of your data, have access to or amend/correct the data that you have given to us, you can send an email to support@cripco.com. We shall retain your personal data for as long as is necessary for the above-mentioned purposes and take reasonable measures to destroy any personal data that is no longer necessary to meet those purposes.

4. #### Cookie

We may use “cookies” to store specific information about you and track your website visits during your use of the Services. Cookies refer to small amounts of data that is sent by the server that operates the website to your computer browser, which may be stored on the hard disk of your computer. They are used to manage security measures, enhance and develop services, offer personalized Services and provide tailored advertisements through analyzing user access, such as the frequency and timing of access, identify patterns in the user’s usage, track user activities, and access to security measures. It is not uncommon for websites to use cookies to enhance identification of their users. You can determine if and how a cookie will be accepted by configuring the browser which is installed in the computer you are using to access the Services. If you choose, you can change those configurations.

5. #### Exercise of Rights

You may access, update, or delete your personal information, as well as choose what communications you would like to receive from us. Depending on your location, you may have additional rights related to your personal information (please refer to “Jurisdiction Specific Provisions” below). You can also choose not to provide us with certain personal information, but that may result in you being unable to use certain features of the Services because that information may be required for you to register for an account, make certain purchases, participate in our promotional offerings, get customer support, or engage in other activities associated with the Services.

### 1. Accessing, Updating, and Deleting Your Personal Information

You can access and update certain personal information about you by visiting your account settings. You can also submit a data privacy request to receive a copy of personal information that we hold about you, free of charge.\
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If you believe any personal information we have on record relating to you is incorrect or incomplete, we will work with you to make corrections as necessary. Please note that we may not accommodate a request to update information if we believe such update would violate any law or legal requirement, or would render such information to be incorrect.\
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If you would like CRIPCO to delete your account or personal information, you can submit a deletion request. Note that when we delete your account, personal information that you have shared with others may still be visible.\
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Please note that CRIPCO may retain and use certain personal information about you where reasonably necessary to comply with our legal and contractual obligations, statute of limitations, resolution of disputes, and enforcement of our agreements and for our legitimate business purposes. This means that we may not be able to delete all of your data upon your request depending on the reasons above and the nature of your interactions.

### 2. Data Privacy Requests and Verification

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You can request to access, update, or delete your personal information by emailing us at \[support@cripco.com] from the email address associated with your account. If you would like to make a request under the privacy laws of your jurisdiction, please let us know where you reside and which rights you would like to exercise. For more information about exercising your jurisdiction-specific privacy rights, please refer to “Jurisdiction Specific Provisions” below.\
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To protect your privacy, we need to verify your identity before we process your data privacy request. As part of this process, you may contact us via the email address associated with your account. Depending on the nature of the request, we may also need to obtain additional information necessary for us to verify your identity. You may designate an authorized agent to make a data privacy request on your behalf. To do so, we will need to receive written permission by you or a valid power of attorney, and we may also verify the validity of the request directly with you.

6. #### Third Party Content

Except as otherwise expressly specified in these Terms, this document only addresses the use and disclosure of personal information CRIPCO collects from you. To the extent you disclose your personal information to other parties through the Services, different rules may apply to how they use and share your personal information. Accordingly, you will need to look at the privacy policies of these third parties to understand their data privacy practices.

We may incorporate links for third-party websites, webpages, or applications in the Services, or use services provided by a third-party when providing the Services. If you use any additional function, plug-in, or application (collectively, “Third-Party Application”) during your use of the Services, such Third-Party Application may obtain your personal data. You acknowledge and understand that we are not involved in any collection of personal data conducted by any Third-Party Applications, as they are not controlled by us. Third-Party Applications may be governed by their own privacy policies and other policies relating to the handling of your personal data.

The Services may contain links to other websites or resources that are operated by third parties not affiliated with CRIPCO. These links and resources are provided as a convenience to you and as an additional avenue of access to the information contained therein. Any facts, views, advice, analyses, opinions, and recommendations expressed or made available by any individual or organization are those of the respective author(s). CRIPCO cannot and do not endorse, and cannot be responsible for such facts, views, advice, analyses, opinions, and recommendations expressed, or advocate any commercial dealing in any securities, investments or classes of securities or investment.

We are not responsible or liable for any content, advertising, products, or other materials on or available from such sites or resources. Inclusion of links to other sites or resources should not be viewed as an endorsement of the content of linked resources.

Different terms and conditions and privacy policies may apply to your use of any linked sites or resources. CRIPCO is not responsible or liable, directly, or indirectly, for any damage, loss or liability caused or alleged to be caused by or in connection with any use of or reliance on any such content, products, or services available on or through any such linked site or resource.

7. #### Jurisdiction Specific Provisions

### 1. Users in the European Economic Area, UK, and Switzerland

We rely on legal bases to transfer information outside of the EEA, UK, and Switzerland. For example, transfers involving personal information of users located outside Singapore are necessary for the performance of the contract between you and WADE CLUB, as established in our Terms and Conditions. With respect to the processing of information by our service providers on our behalf, we take all necessary steps required under applicable law to ensure that their transfer of information across borders is compliant with applicable law.

### 2. Users in the European Union

Under the General Data Protection Regulation (“GDPR”) and other applicable laws, users in the European Union have the right to, under certain conditions, request access to, rectification of, or erasure of their personal information; request restriction of processing; object to processing; withdraw consent from processing; data portability; and submit a complaint to a data protection authority. Such rights are incorporated in this Policy in Appendix 1.

If you are in one of the member countries of the European Union and would like to exercise these rights, please email us at \[support@cripco.com] pursuant to the “Data Privacy Requests and Verification” section above. Please include the phrase “GDPR request” in the subject line and provide us with your mailing address and country of residence.

CRIPCO only collects and processes personal information about you where it has lawful bases for doing so. The specific legal basis applied to the processing will depend on the context in which the personal information is being processed, including the Service used and the type of personal information involved.

CRIPCO uses the following legal bases for processing:

* For the performance of a contract. We will process your personal information to fulfill our contractual obligations with you, such as to provide you with the Service, to communicate with you regarding your use of the Service, and to comply with our Terms of Service.
* For legitimate interests. We will process your personal information for our legitimate interests or those of others (as long as the processing is not outweighed by your data protection interests). This includes but is not limited to, preventing fraud and other abuse, ensuring the security of the Service, protecting our legal rights and interests, conducting market research and product development, and for marketing purposes.
* To comply with legal obligations. We will process your personal information to comply with all applicable laws, regulations, court orders, and government and law enforcement agencies’ requests.
* Consent. We will process your personal information when you have given us consent to do so, such as when you consent to receive certain communications from us.

If you’d like to withdraw your consent or object to our processing of your personal information, please contact us at \[support@cripco.com].

If you believe that we have not adequately addressed your concerns or wish to report an alleged infringement of applicable data privacy laws, you may file a complaint with your local supervisory authority.

### 3. Users in California

If you are a California resident, you have specific privacy rights governed by the California Consumer Privacy Act (“CPRA”). These rights include:

* Right to Know. You have the right to request a report showing the personal information collected, shared, and sold about you in the past 12 months.
* Right to Opt-Out of Sale of Your Personal Information. You have the right to opt-out of the sale of your personal information to third parties.
* Right to Deletion. You have the right to request that we delete any personal information collected from you.
* Right to Limit the Use and Disclosure of Sensitive Personal Information. You have the right to request that we limit the use and disclosure of any sensitive personal information that we collected from you.
* Right to Non-Discrimination. We shall not discriminate against you based on your exercise of any of the above rights.

You or your authorized agent may submit a request to exercise any of the above rights by emailing us at \[support@cripco.com] with the subject line “CPRA Request”. Please also provide us with your mailing address and state of residence.

We may require additional information to verify your identity or to verify that your authorized agent has the authority to make the request on your behalf before responding to a CPRA rights request. We will respond to your request within 45 days if possible and required under the law.

Under California’s “Shine the Light” law, California residents have the right to request certain information relating to personal information we have shared with third parties for those third parties’ direct marketing purposes. Note that we only share information with third parties for their direct marketing purposes is requested or expressly consented to by you.

If you are a California resident and would like to exercise your rights under the CPRA or California’s ‘Shine the Light’ law, email us at \[support@cripco.com] pursuant to the “Data Privacy Requests and Verification” section above. Please specify which privacy right you are exercising in the subject line (for example “CPRA deletion request”) and provide us with your mailing address and state of residence.

8. #### Children's Information

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity. CRIPCO does not knowingly collect any personal identifiable information from children under the age of 18. If you think that your child has provided this kind of information via the Services, we strongly encourage you to contact us and we will use our best efforts to promptly remove such information.

9. #### Contact Us

For more information about our Terms in regards your privacy rights or our data collection or processing practices, if you have any questions, or if you would like to make a complaint, please contact us by e-mail at support@cripco.com.

10. #### Changes to Privacy Policy

We keep our Terms under regular review and place any updates if necessary. This Privacy Policy was last updated on \[07/02/24].   Appendix 1: EU GDPR Privacy Assurance Policy

Section 1. Lawful Management of Personal Data under GDPR We lawfully process personal data under the conditions below:

1. A user explicitly consents to their personal data being processed.
2. The processing is necessary for executing a contract that a user is part of or for initiating steps required by a user before entering into a contract. This may involve member management, identification, service provision, payment, and settlement of fees, among others.
3. The processing is a legal requirement for us, such as adherence to relevant legislation, rules, legal procedures, or governmental requests.
4. The processing is crucial to protect users or other individuals' vital interests, for example, detecting, preventing, and responding to fraud, abuse, security threats, and technical issues that could harm users or other individuals.
5. The processing is necessary for a task conducted in public interest or in the execution of official authority given to us.
6. The processing is essential for the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or basic rights and freedoms of the data subject, especially where the data subject is a child.

Section 2. GDPR Rights of Users Users or their legal representatives have the following rights in relation to the collection, use, and sharing of personal data by us:

1. Right to access personal data: Users or their legal representatives can request access to their data and verify the records of the collection, usage, and sharing of their data under the law.
2. Right to correction: Users or their legal representatives can request corrections for any inaccurate or incomplete data.
3. Right to deletion: Users or their legal representatives can request the deletion of their data after the completion of its purpose and the revocation of their consent.
4. Right to restrict processing: Users or their legal representatives can request a temporary suspension of data processing in the event of disputes over data accuracy and the legality of data processing, or if data retention is necessary.
5. Right to data portability: Users or their legal representatives can request the provision or transfer of their data.
6. Right to object: Users or their legal representatives can object to data processing if the data is used for direct marketing, legitimate interests, official duty execution, and research and statistics.
7. Right to avoid automated individual decision-making, including profiling: Users or their legal representatives can request to stop automated processing of personal data, including profiling, which significantly impacts or can legally affect them.

Section 3. Data Transfer Across Borders Given our worldwide operations, users' personal data may be shared with entities in other countries for explicitly stated purposes in this Policy. In regions where personal data is transferred, stored, or processed, we enforce adequate measures to protect the data. If personal data from the European Union or Switzerland is used or disclosed, we align with the US-EU Privacy Shield, Swiss-US Privacy Shield, or employ other measures or secures user consent following EU regulations, using a standardized agreement clause approved by EU executing organizations or ensuring suitable safeguards.

Section 4. Third-Party Sites and Services Our websites, products, or services may include links to third-party websites. The privacy policies of these third-party sites may be different from ours. Users are therefore advised to review the privacy policies of any third-party sites accessed via links on our site.

Section 5. Policy Updates We have the right to update this Privacy Policy as needed. If significant changes are made, We will notify users via the website or other suitable means, providing users with a chance to review the changes before they become effective. If a user continues to use our services after changes have been notified, it will be regarded as the user's acceptance of the changes.

Section 6. Contact Information For users or their legal representatives wishing to exercise their rights as described in this Policy, or for those with any queries or complaints about our privacy practices, they can reach out to our Data Protection Officer or equivalent representative through the contact information available on our website.
