At Kickoff (referred to here as “we”, “us” or “our”), we respect and protect the privacy of users and developers (“you” and “your” or “Users” and “Developers”, as relevant) who explore and use Kickoff through our website, platform, tools, smart contract integrations, and related services (collectively, the “Services”).

This Privacy Policy describes how we collect, use, and disclose personal information when you use our Services, which include the services offered on our website kickoff.fun (“Site”). This Privacy Policy does not apply to any processing which Kickoff carries out as a processor on behalf of those Users and Developers who explore and use Kickoff.

Please note that we do not control websites, applications, or services operated by third parties, and we are not responsible for their actions. We encourage you to review the privacy policies of the other websites, decentralized applications, and services you use to access or interact with our Services.

This Policy supplements the Kickoff Terms of Use and Legal Disclosure. By accessing or using the Platform, you acknowledge that you have read, understood, and agreed to this Privacy Policy.

#1. What Information We Collect

We collect and process the following personal information when providing the Services:

Information you provide to us

We collect information that you provide to us directly when using the Services.

• Wallet Address: Your public wallet address
• Basic User Information: Your name, email address, social media handle(s) (including your Discord username/ID), business name (where relevant)
• Application Information: When you apply for Kickoff programmes, we may ask for date of birth, nationality, country of residence, professional/crypto experience, job title, language proficiency, location/timezone
• Project Information: Project/team/company name, project category (e.g. NFT, DeFi, gaming or social), project description, creator name, link to website/dapp, wallet address, social media handles, content representing creators/artists
• Feedback Information: Any feedback or suggestions you provide to us on the Services

Information collected automatically

We collect certain information automatically when you use or explore Kickoff.

• App, Browser and Device Information: Information about the device, operating system, and browser you're using, other device characteristics or identifiers (e.g. plugins, the network you connect to), IP address/derived location information
• Information from cookies and similar technologies: See Section 2 for further information about our use of cookies

Information we obtain from third parties

We also receive certain information about you from third parties.

• Blockchain Data: We may analyze public blockchain data, including timestamps of transactions or events, transaction IDs, digital signatures, transaction amounts, wallet addresses, and verifications (onchain attestations)
• Information from Analytics Providers: We receive information about your website usage and interactions from third party analytics providers. This includes browser fingerprint, device information, and IP address
• Error Tracking Data: We utilize information from third party service providers to provide automated error monitoring, reporting, alerting and diagnostic capture for Service and Site errors to allow Users or Developers to build more effectively on the Kickoff platform
• Public Database Information: We also obtain information about you from public databases, such as sanctions lists maintained by public authorities, media reports, and other data as necessary

#2. Cookies and Similar Technologies

We use cookies and similar tracking technologies to collect and use personal information about you, including to serve interest-based advertising. For further information about the types of cookies we use, why, and how you can control cookies, please see the details below.

We use cookies and similar technologies to:

• Remember your preferences and settings
• Analyze Platform usage and improve functionality
• Provide security and prevent fraud
• Deliver personalized content and experiences
• Measure the effectiveness of our Services

You can control cookies through your browser settings, though disabling cookies may limit Platform functionality.

#3. How We Use Your Information

We may use your personal information for the following purposes or as otherwise described at the time of collection. If you reside outside the United Kingdom or European Economic Area (“EEA”), the legal bases on which we rely in your country may differ from those listed below.

To provide you with the Kickoff Services

We use certain information that is necessary to conclude and perform our Terms of Service or other relevant contract(s) with you.

• Information Used: Wallet Address, Basic User Information, Blockchain Data
• Legal Basis: Contractual Necessity

To allow Users and Developers to build more effectively on the Kickoff platform

We process certain information to identify issues with, and potential improvements to, our Services.

• Information Used: Error Tracking Data, Information from Analytics Providers
• Legal Basis: Legitimate Interests

To consider your applications to Kickoff programmes and to administer and facilitate your participation

We may review your information provided in applications to determine your eligibility for programmes.

• Information Used: Wallet Address, Basic User Information, Application Information, Project Information, Public Database Information
• Legal Basis: Legitimate Interests

To promote and market Developers' dapps and projects

We review Developers' dapps and projects to assess whether they can potentially be featured in promotional, marketing or other materials.

• Information Used: Project Information
• Legal Basis: Legitimate Interests

To provide marketing communications to you

We use your information to send you marketing communications.

• Information Used: Basic User Information, Project Information
• Legal Basis: Legitimate Interests

To promote the safety, security and integrity of our Services

To verify wallet addresses and related activity, find and address violations of our Terms of Service, detect fraudulent behaviour and to maintain the integrity of our Services.

• Information Used: Basic User Information, Information from Analytics Providers
• Legal Basis: Contractual Necessity

To obtain your feedback on the Services

We use certain information to send you surveys and otherwise obtain your feedback for marketing and product development purposes.

• Information Used: Basic User Information, Feedback Information
• Legal Basis: Legitimate Interests

To comply with legal and regulatory obligations

We may access, read, preserve, and disclose information when we believe it is reasonably necessary to comply with law, legal obligations, regulations, law enforcement, governmental, and other legal requests and court orders.

• Information Used: Wallet Address, Basic User Information, Application Information, Project Information
• Legal Basis: Legitimate Interests

#4. How and Why We Share Your Information

We share certain information about you with service providers, partners and other third parties in order to help us provide our Services. Here's how:

Linked Third Party Websites or Services

When you use third-party services (like when you connect your self-custodial wallet to decentralized applications on the Base network) or websites that are linked through our Services, the providers of those services or products may receive information about you (like your wallet address) from Kickoff, you, or others. Please note that when you use third-party services or connect to third-party websites which are not governed by this Privacy Policy, their own terms and privacy policies will govern your use of those services and products.

Professional advisors, industry partners, authorities and regulators

We share your information described in Section 1 with our advisors, regulators, tax authorities, law enforcement, government agencies, and industry partners when needed to:

• Respond pursuant to applicable law or regulations, court orders, legal process or government requests
• Detect, investigate, prevent, or address fraud and other illegal activity or security and technical issues
• Protect the rights, property, and safety of our Users, Developers, or others, including to prevent death or imminent bodily harm

Vendors and Third-Party Service Providers

When we share information with third-party service providers to help us provide our Services, we require them to use your information on our behalf in accordance with our instructions and terms and only process as necessary for the purpose of the contract.

#5. How Long We Retain Your Personal Information

We retain your information as needed to provide our Services, comply with legal obligations or protect our or others' interests. While retention requirements vary by country, we maintain internal retention policies on the basis of how information needs to be used. This includes considerations such as when the information was collected or created, whether it is necessary in order to continue offering you our Services or to protect the safety, security and integrity of our Services, and whether we are required to hold the information to comply with our legal obligations.

Please note that blockchain data cannot be deleted due to the immutable nature of distributed ledgers.

#6. Children's Personal Information

The Services are not directed to persons under the age of 18, and we do not knowingly request or collect any information about persons under the age of 18. If you are under the age of 18, please do not provide any personal information through the Site or Services. If a User submitting personal information is suspected of being younger than 18 years of age, we will take steps to delete the individual's information as soon as possible.

#7. International Transfers

To facilitate our global operations, we and our third-party partners and service providers may transfer and store data throughout the world, including in the United States.

If you reside in the EEA, Switzerland, or the United Kingdom, we rely upon a variety of legal mechanisms to facilitate these transfers of your personal information (collectively, “European Personal Data”). We rely primarily on the European Commission's Standard Contractual Clauses to facilitate the international and onward transfer of European Personal Data to third countries. We also rely on adequacy decisions from the European Commission where available and exemptions provided for under data protection law (e.g. Article 49 GDPR).

#8. Your Privacy Rights and Choices

Depending on where you live, you may be able to exercise certain privacy rights related to your personal information. You can make privacy rights requests relating to your personal information by contacting us at hello@kickof.fun. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, Kickoff has absolute discretion in providing you with these rights.

Right to access and portability: You may request that we provide you a copy of your personal information held by us by submitting a request via hello@kickof.fun.

Right to rectification: You may request us to rectify or update any of your personal information held by Kickoff that is incomplete or inaccurate by submitting a request via hello@kickof.fun.

Right to deletion/erasure: You may request to erase your personal information, subject to applicable law. Note that blockchain data cannot be deleted.

Right to withdraw your consent: To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. The lawfulness of Kickoff's processing before you withdraw your consent will not be affected by such withdrawal.

Right to object to or restrict processing: You may have the right to restrict or object to us using or transferring your personal information based on our legitimate interests, in the public interest, or for direct marketing. We may continue to process your personal information where permitted or required by applicable law. You can opt-out of receiving marketing communications from Kickoff by submitting a request via hello@kickof.fun.

Right to non-discrimination: We will not discriminate against you for exercising any of your rights provided to you under law.

Right to lodge a complaint: If you reside in the EEA, Switzerland, or the UK, you have the right to lodge a complaint about our practices with respect to your personal information with the supervisory authority of your country or state.

To protect your privacy and security, we may take steps to verify your identity before complying with your request and we may decline your request if we are unable to verify your identity.

Under certain US data privacy laws, as well as in Brazil, you may also designate an authorized agent to make these requests on your behalf.

These rights are not absolute, and may be denied: (a) when granting access or assisting portability would adversely affect the rights and freedoms of others (b) to protect our rights and properties; (c) where the request is frivolous or vexatious; or (d) as otherwise permitted by law.

#9. How to Contact Us With Questions

If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, please contact us at hello@kickof.fun.

#10. Changes to This Privacy Policy

We're constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well. We post any changes we make to our Privacy Policy on this page and, where appropriate, we will provide you with reasonable notice of any material changes before they take effect or as otherwise required by law. The date the Privacy Policy was last updated is identified at the top of this page.