Privacy Policy

Version 1.0

Districts.xyz (“Districts,” “we,” “us,” and “our”) is a decentralized platform, offering an avenue for users to own virtual land and build on it.

Our Privacy Policy (“Privacy Policy”) is designed to help you understand our practices regarding the collection, use, and disclosure of certain information, including your personal information, and to assist you in exercising your privacy rights.

SCOPE

This Privacy Policy applies to information processed by us in the course of our business, including on our websites and applications (collectively, the “Districts Platform”) and our related online and offline offerings (collectively, the “Services”).

INFORMATION WE COLLECT

When you use our Services, we may collect the following kinds of information:

INFORMATION YOU PROVIDE TO US

Account Information. If you connect your Web3 and create a profile through our Services as an authorized user, you may provide us with personal information (also known as “personally identifiable information” or “personal data” under applicable laws). This may include your username, email address, profile photo or image, and device type. The user name that you associate with your account will be considered personal information if either item personally identifies you.

Your Communications with Us. We collect personal information from you like your email address, name, device type, etc. whenever you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us.

Our Virtual World. When you use the Districts Platform, you can create and customize your virtual land and visit virtual lands created by others. The Districts Platform will allow tools to create and upload images, and all manner of content (collectively, “Content”) into the land so that you may easily share and collaborate with other individuals. We collect and store data describing the images and the Content uploaded to our Virtual World.

Interactive Features. We may offer interactive features such as forums, blogs (Districts Digest), chat and messaging services, and social media pages on the Services. We and others who use our Services may collect the information you submit or make available through these interactive features. Any Content you provide via the public sections of these features will be considered “public” and may not be subject to the privacy protections referenced herein. By using these interactive features, you assume the risk that the personal information provided by you may be viewed and used by third parties for their own purposes.

Purchases, Wallet and Transaction Information. In order to engage in transactions or purchases on the Services, you may need to provide a third-party payment processor with your payment information and allow us to connect to your digital wallet by providing us with your public wallet address. We will never ask you for your private keys or collect your private keys. We do not directly collect or store any payment card information entered through our Services or access your digital wallet, but we may receive from a third-party payment processor information associated with your payment card information (for example, your billing details). We may also collect your name, the name of the recipient, email address, the currency and the date as part of the transactions taking place on the Services.

We will also keep a record of your Districts-related transactions, like Land minting, Land claiming, Land selling or purchasing, and transactions involving the Land Bank.

Surveys. We may contact you to participate in surveys. If you decide to participate, you will be asked to provide information that may include personal information.

Registration for Sweepstakes or Contests. We may run sweepstakes and contests. Contact information you provide may be used to inform you about the sweepstakes or contest and for other promotional, marketing, and business purposes if permitted by law. In some jurisdictions, we are required to publicly share information about winners.

Conferences and Trade Shows. We may attend conferences and trade shows where we collect personal information from individuals who interact with or express an interest in Districts or the Services. If you provide us with any personal information at one of these events, we will use it for the purposes for which it was collected. This may include targeted follow-up marketing of Districts or the Services.

Business Development and Strategic Partnerships. We may collect and use personal information when we collaborate with other parties on extensions and enhancements to the Services or the Districts Platform. These other parties would have access the personal information.

Job Applications. We may post job openings and other community participation opportunities on the Services and/or Districts. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and process the information contained in those submissions, which includes personal information, to assess your suitability, aptitude, skills, and qualifications for employment. We may store this information to identify candidates for future job openings and opportunities.

INFORMATION COLLECTED AUTOMATICALLY

Automatic Data Collection. We may collect certain personal information automatically when you use the Services. This personal information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information (including inferred location-based on your IP address), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, information about how you interact with the Services, including the frequency and duration of your activities, and other information about how you use the Services. Personal information we collect may be associated with accounts, other devices, and Districts.

• Cookies, Pixel Tags/Web Beacons, and Personalized Advertising. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect personal information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with the Services.
• Cookies. Cookies are small text files placed in visitors' device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Services that collects information about users' engagement. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on particular content. We may also include pixel tags in emails to understand whether messages have been opened, acted on, or forwarded.
• Analytics. We use service providers such as Google Analytics and may use others to collect anonymized or aggregate information regarding user behavior and user demographics on the Services. For more information about Google Analytics, please visit https://www.google.com/policies/privacy/partners/. You can opt out of Google's processing of data generated by your use of the Services by visiting https://tools.google.com/dlpage/gaoptout.

INFORMATION FROM OTHER SOURCES

We may obtain personal information about you from other sources, including through third-party services. Districts may allow you to use our Services through third-party login services like Google. If you use our Services with a third-party log-in service, we will receive basic information tied to the account, such as your email address, full name, profile photo, and unique user IDs or tokens used by the third-party service. We will also receive files and other information from these third-party services that you specifically link to while using the Services, such as files from Google Drive, Google Docs, or Dropbox.

HOW WE USE YOUR INFORMATION

We use your personal information for a variety of business purposes, including:

• Providing the Services or requested information;
• Fulfilling our contract with you;
• Managing your information;
• Processing payment card and/or other financial information (through a secure third-party payment processor) to facilitate your use of the Services;
• Processing your Web3 wallet transactions to facilitate your use of the Services;
• Responding to questions, comments, and other requests;
• Providing access to certain areas, functionalities, and features of the Services;
• Answering requests for customer or technical support; and
• Allowing you to register for events.

Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at: https://support.realio.network/hc/en-us/requests/new?ticket_form_id=34409612652315 any time, as set forth below.

Consent. We may use personal information for purposes disclosed to you at the time of collection or with your explicit consent. At any time, you have the right to revoke your consent with respect to our collection, use, or disclosure of your personal information.

De-identified and Aggregated Information Use. We may strip out personal identifiers and use your remaining personal information to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, de-identified or aggregated trends, reports, or statistics, or other analyses we create, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

Sharing Content/Land and Profiles with Friends, Colleagues, and Third Parties. We offer various tools and functionalities to share your Profile, Content, and personal information with others through a unique URL. Your Districts profile consists of the user name that you choose and the image that you wish to use, whether these are identifiable to you (like a photo) or not (collectively, your “Profile”). Your Profile is publicly visible and searchable. You may choose to share your lands with other users and third parties along the lines of what you do on other social media sites. Most creators in Districts wish to share their Profile (including their Content) with users, third parties, and other social media sites to obtain followers. You can affirmatively choose to keep your Profile private by toggling to ensure it is not publicly listed. In this manner, you can control those to whom your land is visible.

In addition, we may, at some point, allow you to provide personal information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.

HOW WE USE THE AUTOMATIC COLLECTION TECHNOLOGIES.

Our uses of the automatic collection Technologies fall into the following general categories:

• Operationally Necessary. This includes Technologies employed when you access Services that are required to identify irregular behavior, prevent fraudulent activity, and improve security or that otherwise are needed to make use of the Districts platform or services.
• Performance Related. We may use the Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
• Functionality Related. We may use the Technologies when you respond to our offers of enhanced functionality when accessing or using Services. This may include identifying you when you sign into our Services and keeping track of your specified preferences or past pages viewed;
• Advertising or Targeting Related. We may use our own Technologies or third-party Technologies to develop and deliver content, including ads relevant to your interests, on our Services, or on third-party sites. Depending on applicable law, we may seek your express consent to such ads. We do not sell your personal information; and
• Cross-Device Tracking. Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this, our technology partners may share data, such as your browsing patterns, geo-location, and device identifiers, and will match the personal information of the browser and devices that appear to be used by the same person.

DISCLOSING YOUR INFORMATION TO THIRD PARTIES

We may share your personal information with the following categories of third parties:

• Service Providers. We may share any personal information we collect about you with our third-party service providers. The types of service providers to whom we entrust information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment and transaction processing; (v) customer service activities; and (vi) the provision of technical support and related services. We do so in accordance with applicable law, which may require data processing agreements or addenda.
• Business Partners. We may provide personal information to business partners to provide you with a product or service you have requested. We may also provide personal information to business partners with whom we jointly offer products or services.
• Advertising Partners. Through our Services, we may allow third-party advertising partners to set Technologies and other tracking tools to collect personal information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day) and also information we actively or automatically have collected. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third-party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” Depending on your place of domicile and applicable law, we may request your express consent to undertake such activities. Wherever you may be located, if you prefer not to share your personal information with third-party advertising partners, you may opt-out by visiting the “settings” menu in the Districts Platform.
• Information Shared with Other Users. When you use the Services, personal information will be accessible to other users and the public/third parties. This personal information will include your Profile (which may include personal information) and may include Content you choose to present via public listing, including any audio or images of you or your surroundings. Please be aware that Districts has little or no control over how individuals may use the Content you share.
• APIs and Software Development Kits. We may use third-party application programming interfaces, or APIs, and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties to collect your personal information, subject to applicable law, to provide Content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.
• Disclosures to Protect Us or Others. We may access, preserve, and disclose any personal information we store in association with you to external parties if we believe, in good faith, doing so is required or appropriate for the following purposes:
1. to comply with law enforcement or national security requests and legal process, such as a court order or subpoena;
2. to protect your, our, or others' rights, property, or safety;
3. to enforce our policies or contracts;
4. to collect amounts owed to us; or
5. to assist with an investigation and prosecution of suspected or actual illegal activity.
• Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your personal information may be used for due diligence or transferred as part of such a transaction as permitted by law and/or contract.

INTERNATIONAL DATA TRANSFERS

You agree that all personal information processed by us may be transferred, processed, and that may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws. If you are a resident of the European Economic Area (EEA), Switzerland, or the United Kingdom and provide personal data to us, we will either seek your express consent to such transfer if you are an individual data subject in accordance with applicable law, or we will rely on mechanisms such as the applicable Standard Contractual Clauses.

YOUR CHOICES

General. You may have the right to opt into certain uses of your personal information. Or, based on your type of use or your geographic location, you may have the right to object to or opt out of certain uses of your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time by contacting us as described below.

Email Communications. If you receive an unwanted email from us, you can use the “unsubscribe” link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (for example, communications regarding the Services or updates to this Privacy Policy).

“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Depending on your domicile and applicable law, we may seek your express consent to the placement of cookies. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt out of personalized advertisements on some mobile applications by following the instructions for Android and iOS. The online advertising industry also provides websites on which you may opt out of receiving targeted ads from multiple advertisers that participate in self-regulatory programs. You can access these and also learn more about targeted advertising and consumer choice and privacy, at https://www.networkadvertising.org/managing/opt_out.asp, https://www.youronlinechoices.eu/ and https://www.aboutads.info/choices/.

Please note you must separately opt out in each browser and on each device.

YOUR PRIVACY RIGHTS

You have the right to do any of the following:

• Limit the use and disclosure of sensitive personal information: you can direct businesses to only use your sensitive personal information for limited purposes, such as providing you with the services you requested.
• Request restriction to use of your personal information or its processing, including the right to opt in or opt out of the sale and sharing of your personal information to third parties.
• Request correction of your personal information where it is inaccurate or incomplete.
• Request disclosure of: 1) the categories and/or specific pieces of personal information we have collected about you, 2) the categories of sources for that personal information, 3) the purposes of that information, 4) the categories of third parties with whom we disclose the information and 5) the categories of information that we sell or disclose to third parties.
• Access personal information about you consistent with legal requirements. In addition, you may have the right, in some cases, to receive or have your electronic personal information transferred to another party.
• Request deletion of your personal information, subject to certain exceptions prescribed by law.
• Equal treatment: you cannot be discriminated against for exercising your privacy rights.

If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

DATA RETENTION

We retain the personal information we have received as described in this Privacy Policy for as long as you use our Services and as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

SECURITY OF YOUR INFORMATION

We take steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy. We use appropriate technical, organizational, administrative, logical, physical, and managerial measures to safeguard your personal information against loss, theft, and unauthorized access, use, and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information. Unfortunately, no measures can be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us.

To the extent permitted by applicable law, by using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system's breach, we may attempt to notify you electronically by sending a notice through the Services or by sending an email to you.

THIRD-PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications, and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of, such other websites or applications. Visiting these other websites or applications is at your own risk.

NOTICE REGARDING USE OF BLOCKCHAIN

Transactions involving $RIO, $DSTRX, Land Pixels, Land Bank, other NFTs, etc. on the Districts Platform will be conducted on the relevant blockchain protocol. Information about your transfers will be provided to the blockchain and may be accessible to third parties due to the public nature of the blockchain. Because of the public nature of entries to the blockchain and because it may be possible for someone to identify you through your pseudonymous, public wallet address using external sources of information, any transaction you enter onto the blockchain could possibly be used to identify you, or information about you. Please note that once your information is uploaded onto or otherwise recorded on the blockchain, it cannot be deleted.

CHILDREN'S INFORMATION

The Services are not directed to persons under 16 (or to children otherwise protected by applicable law), and we do not knowingly collect personal information from children. We will try to establish that you are at least 16 years old; if you are not, you will be instructed not to misrepresent your age or use the Services. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any child's personal information in violation of applicable law, we will promptly take steps to delete such information.

SUPERVISORY AUTHORITY

If you are located in the European Union, Switzerland or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

CHANGES TO OUR PRIVACY NOTICE

We may revise this Privacy Policy from time to time at our sole discretion, and such revisions may reflect compliance with applicable law as it changes. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

CALIFORNIA CONSUMER PRIVACY ACT (CCPA) PRIVACY NOTICE

This CCPA Privacy Notice applies to California consumers and supplements the Privacy Notice. We do not sell personal information. For purposes of the CCPA, we have collected the following categories of consumers' personal information in the last 12 months:

We use the collected personal information for the following commercial and business purposes: (1) to provide and improve the Services; (2) for marketing purposes; (3) for fraud prevention and legal purposes; (4) to secure the Services; and (5) for audit purposes. Personal information within each of the categories may be shared with the following categories of third parties: (1) service providers; (2) business partners; (3) advertising partners; and (4) other users. The categories of personal information are shared for the commercial and business purposes listed above.

CONTACT US

If you have any questions about our privacy practices or this Privacy Notice, please contact us at:

Districts
123 Main Street, 2nd Floor,
Road Town Tortola VG1110
BVI
[email protected]

EU DATA PROTECTION OFFICER

VeraSafe has been appointed as Districts representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. If you are in the European Economic Area, VeraSafe can be contacted in addition to [email protected], only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +420 228 881 031.

Alternatively, VeraSafe can be contacted at:

VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P
Ireland

UK DATA PROTECTION OFFICER

VeraSafe has been appointed as Districts representative in the United Kingdom for data protection matters, pursuant to Article 27 of the United Kingdom General Data Protection Regulation. If you are located within the United Kingdom, VeraSafe can be contacted in addition to or instead of [email protected], only on matters related to the processing of personal data. To make such an inquiry please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +44 (20) 4532 2003.

Alternatively, VeraSafe can be contacted at:

VeraSafe United Kingdom Ltd.
37 Albert Embankment
London SE1 7TL
United Kingdom