Privacy Policy

Latest Update: 19th September 2024

Introduction

This Privacy Policy explains what personal data we gather about you and how we process your personal data on the basis of your use of our Website or through your use of our services, which services include campaigns, surveys and competitions which we launch from time to time.

When we refer to “we” or “us” this refers to HX Entertainment Limited, a company registered in Malta with company registration number C 77290, and with the registered address at 14 East, Level 7, Triq Tas-Sliema, Gzira, GZR 1639, Malta which operates under the brand name “chiliz”. HX Entertainment is the data controller, being the company that’s responsible for your privacy pursuant to this Privacy Policy. When we refer to “our Website” or “this Website” or “our Site” in this Privacy Policy we mean the specific webpage of chiliz – https://www.chiliz.com. In this Privacy Policy, your information is called “personal data” or “personal information”. We also collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.

Any queries relating to this Privacy Policy and any other aspects of your data privacy can be addressed to us at dataprotection@chiliz.com.

a. What personal data do we process?

Our Site is designed in such a manner that it makes it possible for users to visit and use our Website without disclosing or revealing any personal information about themselves. However, you may choose to provide us with personal information when you contact us via the ‘Contact Us’ page on our Website. Should this occur, we oblige ourselves to process any such personal data that you may provide in full accordance with all applicable data privacy laws, and in such a manner that is necessary for us to be able to respond and administer any request that you may make. You may also decide to provide us with your personal information when signing up or participating in surveys, campaigns, competitions or other activities organized by us. The personal information so collected normally includes your full name as well as your contact details which shall all be processed strictly in accordance with this Privacy Policy and in such a manner to ensure the proper conduct of the survey, campaign, competition or other activity concerned. From time to time, we may further process your personal data to provide you with information about developments taking place in our business industries, and which we feel may be of interest to you. However, this will be subject to you giving us prior consent for such personal data processing. Please inform us by sending an email to dataprotection@chiliz.com if you do not wish to receive such information from us. Furthermore, we are entitled to request from you, at any point in time, information and/or other documentation that we, in our sole discretion, deem fit and necessary in order to comply with any applicable law or regulation in connection with the holding and using of chiliz tokens ($CHZ). We also gather other information when you access our Website. To find out more about how we use cookies, please read the dedicated section below and our Cookie Notice available on https://www.chiliz.com/cookies-policy/.

b. Retention of personal data

No personal data that we process will be kept longer than necessary and only for the purposes for which it is collected. In particular, we shall retain your personal information for the longer of the following periods:

the end of the relevant campaign, competition, survey or other activity being the purpose for which you have provided your personal data;
any retention period that is required by law (including but not limited to any prevention of money laundering and funding of terrorism legislation that may be applicable); or
the end of the period in which litigation or investigations might arise in respect of your use of our services.

c. Compliance

This Privacy Policy and all other personal data processing we may undertake is in strict accordance with the Data Protection Act (Chapter 586 of the Laws of Malta), and with EU Regulation 2016/679 (General Data Protection Regulation). We will also endeavor to employ all reasonable measures to safeguard the confidentiality and security of all personal data that may be processed by us at any time. Such measures include the following:

Administrative and technical controls to restrict access to personal data on a ‘need to know’ basis;
Physical security measures, such as staff security passes to access our premises;
Technological security measures, including firewalls, encryption and anti-virus software.
Where data is processed by a third-party as outlined in this Privacy Notice, we ensure that such third parties provide sufficient guarantees to implement appropriate technical and organizational measures in such a manner that any processing by them satisfies the legal requirements in terms of applicable data protection laws, including the protection of your rights. Moreover, we also ensure that processing by third parties is governed by an agreement between us and third party which includes the necessary contractual clauses to ensure protection of your personal data. Although we use appropriate security measures once we have received your personal data, we remind you that by its very nature the internet may not always be a secure medium and data sent via the internet can potentially be subject to unauthorised acts by third parties. We cannot guarantee the privacy or confidentiality of any information passing over our Website, nor shall we accept any responsibility or liability whatsoever for the security of your personal data while in transit through the internet.

d. Providing personal data to third parties

We do not pass on your personal data, collected from you as a visitor to our Website, to any third party unless you provide us with your consent to do so. Such disclosure to third parties would be required to provide to you our services, such as running campaigns and competitions which may be conducted with the assistance of third parties. Your refusal to provide such third parties with your personal information may disqualify you from participating in the campaigns or competition concerned. Furthermore, your personal information will be shared with third parties, without the need of obtaining your consent, in the instances indicated below. You will be aware however that personal data sent via the internet may be transmitted across international borders, even where the sender and the receiver of such information are located in the same country. Consequently, data relating to you may be transmitted via a country having a lower level of data protection than that existing in your country of residence. Without prejudice to anything contained in this Privacy Policy, we reserve the right to disclose personal data relating to you to any third party, if such disclosures are necessary “inter alia” for the following purposes:

For the purpose of preventing, detecting or suppressing fraud or any other criminal activity; • Where it is a matter of national or public security;
In the interest of national budgetary, monetary or taxation matters that can arise;
To protect and defend our rights and property or that of users of our Website;
To protect against abuse, misuse or unauthorized use of our Website;
To protect the personal safety or property of users of our Website (e.g. if you provide false or deceptive information about yourself or attempt to pose as someone else, we shall disclose any information we may have about you in our possession so as to assist any type of investigation into your actions);
For any purpose that may be necessary for the performance of any agreement you may have entered into with us; or
As may be allowed or required by or under any law.

e. Third party websites

Our Website may from time to time contain links to both local and international third party websites after obtaining permission from them. Any such links are not an endorsement by us of any information in such website or products and/or services offered through the same. We shall not accept any responsibility whatsoever for the content, use, availability, privacy practices or the content of any such websites. Please note that upon entering such other websites, you become subject to the privacy policy of such other sites. No third party is permitted to link any other website to our website without obtaining our prior consent in writing.

f. Transfers to third countries

As a general principle, the personal data we process about you (collected via any of our Websites or Apps or otherwise) will be stored and processed within the European Union (EU)/European Economic Area (EEA) or any other non-EEA country deemed by the European Commission to offer an adequate level of protection.

In some cases, it may be necessary for us to transfer your personal data to a non-EEA country not considered by the European Commission to offer an adequate level of protection. In such cases, apart from all appropriate safeguards that we implement, in any case, to protect your personal data, we have put in place additional adequate measures. For example, we will ensure that the recipient is bound by the EU Standard Contractual Clauses (the EU Model Clauses) designed to protect your personal data as though it were an intra-EEA transfer, and provide technical and organizational measures as may be required to safeguard your personal data. You are welcome to contact us for more information regarding the adequate safeguards we have in place in relation to such data transfers.

g. Cookies

When you visit the Website or use our App, we can collect information about your access and/or use of the services that we could offer you at some point and our interactions with you through the use of Cookies and similar technologies. For more detailed information including what Cookies are and how and why we process such data in this manner (including the difference between ‘essential’ and ‘non-essential’ Cookies) please read our detailed Cookies Notice. As a reference:

When you visit our Website/App, we use Google stats via Cookies to record our performance and check the effect of online advertising. Cookies are a small amount of data that is sent to your browser and stored on your computer’s hard drive. Only when you use your computer to access our Website/App can the Cookies be sent to your computer’s hard drive.
Cookies are usually used to record the habits and preferences of visitors in browsing the items on our Website/App. The information collected by Cookies is non-registered and collective statistical data and does not involve personal data.
Cookies, which enable the Website/App or service provider system to recognize your browser and capture and recall information, cannot be used to obtain data on your hard drive, your email address, or your personal data. Most browsers are designed to accept Cookies. You can opt to set your browser to reject Cookies, or to notify you as soon as possible if you are loaded on Cookies. However, if you set your browser to disable Cookies, it is possible that you may not be able to launch or use some functions of our Website/App.

To find out more, please read our Cookies Notice at https://www.chiliz.com/cookies-policy/.

h. Direct Marketing

We only send mail messages, emails and other communications (including call and other messaging application) relating to our services or any other services provided by HX Entertainment Limited, its affiliates or their and our partners that you use (e.g. to invite you to events) and marketing on our behalf as well as on the behalf of HX Entertainment Limited, its affiliates and their and our partners where we are authorized to do so at law. In most cases we rely on your consent to do so (especially where we use electronic communications).

If, at any time, you no longer wish to receive direct marketing communications from us please let us know by contacting us at contact@chiliz.com. In the case of direct marketing sent by electronic communications (where we are legally authorised to do so) you shall be given an easy way of opting out (or unsubscribing) from any such communications.

Please note that even if you withdraw any consent you may have given us or if you object to receiving such direct marketing material from us (in those cases where we do not need your consent), from time to time we may still need to send you certain important communications from which you cannot opt out.

i. What are your rights?

Provided you fall within the legal definition of a ‘data subject’ in terms of Chapter 586 of the Laws of Malta and EU Regulation 2016/679, you have the following rights in relation to your personal data:

Obtain confirmation that we are processing your personal data and request access to such personal data we hold about you;
Ask that we update the personal data we hold about you or correct such personal data that you think is incorrect or incomplete;
Ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data;
Withdraw consent to our processing of your personal data (to the extent such processing is based on consent);
Receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format;
Object to our processing of your personal data;
Lodge a complaint. Please see the dedicated section below.

Any request to exercise any of your above rights must be made in writing to us at the following mailing address dataprotection@chiliz.com and must be signed by yourself as the data subject to whom the particular personal data relates to. We shall provide you with access to your personal data, including a copy thereof, at no charge. However, if your requests in exercising your above rights be manifestly unfounded or excessive, in particular repetitive in nature, we reserve the right to charge you an administrative charge (determined at our sole discretion) of which you shall be informed beforehand.

j) Right to enter a complaint

If you have any questions/comments/complaints about privacy or should you wish to exercise any of your individual rights, please contact us by sending an email to the following address: dataprotection@chiliz.com with the subject “PRIVACY REQUEST” or by writing to or contacting us at:

DATA PROTECTION OFFICER

HX Entertainment Ltd.
14 East, Sliema Road, Gzira
GZR 1639, Malta

However, you are reminded that the law grants you a right to lodge a complaint with your local or national data protection authority, provided you are based in an EEA territory. You can find a list of Supervisory Authorities in this link https://www.edpb.europa.eu/about-edpb/about-edpb/members_en. In Malta, this is the Office of the Information and Data Protection Commission, which may be accessed by clicking this link (http://www.idpc.org.mt/).

k. Changes to this Privacy Policy

We reserve the right to unilaterally modify this Privacy Policy at any time, particularly if statutory obligations so mandate or the interest of our users’ security so requires. To let you know when we make changes to this Privacy Policy, we will amend the revision date at the header of this page. The modified Privacy Policy will apply from such revision date. We will not officially notify you about such changes, and it is therefore in your own interest to check this Privacy Policy page from time to time so as to familiarise yourself with any changes.