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Privacy & Policy

Date Last Modified: August 31, 2023 

This Privacy Policy (the “Policy”) describes how Sensei Ltd., a Seychelles international company with registration number 233778 (“Karate Combat,” “we,” “us,” or “our”) collects, uses, shares, and stores personal information of the users of our website, www.karate.com (together with its sub-domains, the “Website”) and on the Karate Combat mobile applications and web application (individually and/or collectively, as the context may require, the “Application”). Capitalized terms used, but not defined, herein shall have the meaning ascribed to them in the Terms of Use accessible at https://www.karate.com/about/terms-conditions (“Terms of Use”). 

By using the Application, the Website, including any products, properties or services of Karate Combat or its affiliates, suppliers or representatives accessible through them (collectively, the “Services”), you accept the terms of this Policy and the Terms of Use and consent to our collection, use, disclosure, and retention of your information as described in this Policy.  If you have not done so already, please also review the Terms of Use. The Terms of Use contain provisions that limit our liability to you and require you to resolve any dispute with us on an individual basis and not as part of any class or representative action. IF YOU DO NOT AGREE WITH ANY PART OF THIS POLICY OR OUR TERMS, THEN PLEASE DO NOT USE ANY OF THE SERVICES. 

Please note that the Services may contain links to third party websites, services and/or vendors (“third party services”). Any access to and use of such a third party service is not governed by this Policy, but instead is governed by the privacy policies of those third parties.  We are not responsible for the practices of such third parties, including the information or content contained therein. The inclusion of a link through any of our Services does not imply that we or our affiliates, suppliers or representatives endorse the practices of such third parties. 

This Policy does not apply to information that you submit to us through email, text message or other electronic message or offline.

If you are visiting or using any Services from the European Union (EU), see our Notice to EU Data Subjects below for our legal bases for processing and transfer of your data. 

INFORMATION WE MAY COLLECT

We get information about you in a range of ways. 

Information You Give Us.  Information we collect from you may include:

  • Contact information, such as the email address you provide to sign up for an airdrop or giveaway, sweepstakes, contest or promotion, which may be used to notify you about existing and upcoming events, products, properties or services, as well as marketing and promotional campaigns;

  • Profile information, such as social media handles or preferences and predictions you share while visiting or using the Services; 

  • Usage information, such as information about how you use, and interact with, the Services;

  • Marketing information, such as the preferences you share regarding marketing communications and details about how you engage with them;

  • Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with the Service, receive support or otherwise correspond with any Karate Combat Parties;

  • Technical information, such as your digital wallet address, application programming interface (API)-key and network information regarding transactions. 

Information Automatically Collected. We may automatically record certain information about how you use Services (we refer to this information as “Log Data“). Log Data may include information such as a user’s domain name, Internet Protocol (IP) address, device and browser type, operating system, the pages or features of such Service to which a user browsed and the time spent on those pages or features, the frequency with which such Service is used by a user, search terms, the links on the Service that a user clicked on or used, the referring URL, the webpage that led a user to the Service and other statistics. We use this information collected from you for delivering and promoting (and/or engaging third parties to deliver and promote) our Services, internal analysis and research to improve the Services.  You hereby allow us to collect, process and store the data as stated in this Privacy Policy, including to improve and enhance the Services by expanding its features and functionality and tailoring it to our users’ needs and preferences.

We may use cookies, local storage or similar technologies to analyze trends, administer Services and track users’ movements around the Services; provided that Users may control the use of cookies and local storage at the individual browser level. 

We also may use automated devices and applications to evaluate usage of certain Services and help offer users an optimized user experience. 

We may use Google Analytics to help us understand how users engage with Services. You can find more information about Google Analytics’ use of personal information here: https://www.google.com/analytics/terms/us.html.  

Mixpanel SDK provides us with the ability to collect statistical data on usage of Services. The Mixpanel privacy policy can be found at: https://mixpanel.com/legal/privacy-policy/.

We may use Facebook SDK to analyze traffic to Services. The Facebook Privacy Policy can be found at: https://www.facebook.com/policy.php. 

Information we will never collect. We will never ask you to share your private keys or digital wallet backup/seed phrase. Never trust anyone that asks you to enter your private keys or wallet backup/seed. 

INFORMATION WE MAY USE 

To provide our service

We will use your personal information in the following ways:

  • To enable you to access and use the Services.

  • To provide and deliver products and services that you may request.

  • To facilitate the processing by our affiliate or suppliers of transactions for specific services (such as the Karate Combat store), and send you related information, including purchase confirmations and invoices.

  • To send information, including confirmations, technical notices, updates, security alerts, and support and administrative messages.

To comply with law

We may use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.  

To communicate with you

We may use your personal information to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.

To optimize services

In order to optimize your user experience, we may use your personal information to operate, maintain, and improve our Services, to respond to your comments and questions regarding the Services, to provide you and other users with general customer service. 

With your consent

We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on the Website or for other Services, you instruct us to take a specific action with respect to your personal information, or for third party marketing communications.

For compliance, fraud prevention, and safety

We may use your personal information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.

INFORMATION WE MAY SHARE

We do not share the personal information that you provide us with other organizations without your express consent, except as described in this Policy. We disclose personal information to third parties under the following circumstances: 

  • Affiliates. We may disclose your personal information to our vendors, suppliers, consultants, payment processors (for the Karate Combat store) and other third-party service providers as necessary to carry out purposes consistent with this Policy.

  • Business Changes. We may share personal information if we do or facilitate a business deal.

  • Compliance with Laws and Law Enforcement; Protection and Safety. We may share personal information for legal, protection, and safety purposes, including:

    • to comply with laws,

    • to respond to lawful requests and legal processes,

    • to protect the rights and property of Karate Combat, its contractors, suppliers, users, customers, and others, including enforcing agreements, policies and terms of use, and

    • in an emergency, which includes protecting the safety of the users, suppliers, representatives and customers of Karate Combat and other persons. 

  • Advisors. We may share information with those who need it to do work for us. These recipients may include third parties who administer and provide Services on our behalf.

  • Third Party Services.  We may share the personal information we collect from you to third party services who provide certain Services, as well as contractors or agents who perform functions on our behalf.  This includes advertising partners, social media platforms and other services, such as who send advertisements to users and prospective users who have a similar profile to users (utilizing, for example, Facebook’s “Custom Audience” or “Google Ads”). Additional Third Party Services include, but are not limited to: 

    • Contentful

    • Verisoul

    • Google Captcha

    • Mailchimp

    • Mixpanel

    • Google Analytics

  • Others. You may permit us to share your personal information with other companies or entities of your choosing. Those uses will be subject to the privacy policies of the recipient entity or entities. 

We may also share aggregated and/or anonymized data with others for their own uses.

Certain Karate Combat affiliates, suppliers, vendors and contractors have offices outside of the EU, including, without limitation, suppliers, vendors and contractors in the United States and in other countries. Your personal information may be transferred to or from the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction of residence.

EU users should read the important information provided below about transfer of personal information outside of the European Economic Area (EEA).

HOW INFORMATION IS SECURED 

We retain information we collect as long as it is necessary and relevant to fulfill the purposes outlined in this Policy. In addition, we retain personal information to comply with applicable law where required, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Use, and other actions permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

We employ commercially reasonable precautions to protect the security of all information submitted through the Services from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Security measures will be reviewed from time to time, having regard to the technology available, the cost, and the risk of unauthorized access. 

However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, biometrics, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our Services, including the Application. In order to protect you and your data, you should take steps to protect against unauthorized access to your password, phone and computer.  

INFORMATION CHOICES AND CHANGES

Accessing, Updating, Correcting, and Deleting your Information

You may access information that you have voluntarily provided through your account on the Services, and to review, correct, or delete it by sending a request to [email protected] with subject line “Accessing, Updating, Correcting, and Deleting Information”. You can request to change contact choices, opt-out of our sharing with others, and update your personal information and preferences.  Please note that, regardless of your request, we may still use and share certain information as permitted by applicable law.  

Tracking Technologies Generally

Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. 

Google Analytics

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.

2-Factor Authentication

Where possible, we recommend implementing 2-factor authentication and making sure to back up your cryptographic keys and recovery phrase.  We are not responsible for any lost, stolen, or compromised passwords, cryptographic keys, and recovery phrases, or for any activity on your account via unauthorized password activity.  

CONTACT INFORMATION. We welcome your comments or questions about this Policy, and you may contact us at: [email protected]

CHANGES TO THIS POLICY. We reserve the right to change this Policy at any time without prior notice to you.  Any modifications to this Policy will be effective upon our posting of the new terms and/or upon implementation of the changes (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Policy indicates your acceptance of the terms of the modified Policy. If you do not agree to any changes, your sole remedy is to cease using the Services. If you breach the Policy, your authorization to access the Services shall automatically terminate.

NOTICE TO CALIFORNIA RESIDENTS: Under California Civil Code Section 1789.3, California users are entitled to the following consumer rights notice: California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.  This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

For more details about the personal information we collect from you, please see the “INFORMATION WE MAY COLLECT” section above. We may collect this information for the business and commercial purposes described in the “INFORMATION WE MAY USE” section above. We may share this information with the categories of third parties described in the “INFORMATION WE MAY SHARE” section above. Karate Combat does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). 

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by attempting to contact us at [email protected] with subject line “CCPA Request”. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.

NOTICE TO EU DATA SUBJECTS

Personal Information

With respect to EU data subjects, “personal information,” as used in this Policy, is equivalent to “personal data” as defined in the European Union General Data Protection Regulation (GDPR).

Sensitive Data

Some of the information you provide us may constitute sensitive data as defined in the GDPR (also referred to as special categories of personal data), including identification of your race or ethnicity on government-issued identification documents.

Legal Bases for Processing

We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. 

Processing Purpose

Legal Basis

To communicate with you

To optimize the Services

To provide our service

Our processing of your personal information is necessary to execute any airdrop, giveaway, game or transaction that users elect to participate in.

To communicate with you

To optimize the Services

For compliance, fraud prevention, and safety

To provide our service

These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impacts on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted to by law).

To enforce the Terms of Use, comply with law and exercise or defend legal claims

We may use your personal information to comply with applicable laws and our legal obligations.

With your consent

Where our use of your personal information is based upon your consent, you have the right to withdraw it anytime in the manner specified herein or in the Terms of Use.

Use for New Purposes

We may use your personal information for reasons not described in this Policy, where we are permitted by law to do so and where the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will explain the applicable legal basis for that use. If we have relied upon your consent for a particular use of your personal information, we will seek your consent for any unrelated purpose.

Your Rights

Under the GDPR, you have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

  • Opt-out. Stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you Service-related and other non-marketing communications.

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.

  • Correct. Update or correct inaccuracies in your personal information.

  • Delete. Delete your personal information.

  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.

  • Restrict. Restrict the processing of your personal information.

  • Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You may submit these requests to [email protected] with the subject line “GDPR Request”, together with specific information to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may attempt to contact us at [email protected] or submit a complaint to the data protection regulator in your jurisdiction. 

Cross-Border Data Transfer

Please be aware that data protection laws in the U.S. may be different from those in your country of residence. 

Whenever we transfer your personal information out of the EEA to the U.S. or countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for personal information.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Services may become inaccessible or not function properly.