Privacy Policy

Last updated on November 14, 2022.

This is the privacy policy of Natural Selection Group Limited. (“Company” or “We”). This "Privacy Policy" summarizes what personal information we collect and how we use and disclose this information.

By using our website https://crossbell.io (the “Site”), you signify your consent to the terms of our Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use this Site or submit any personal information to us. This Privacy Policy also describes certain choices you have on how we use your personal information.

We reserve the right to modify this Privacy Policy at any time. We will reflect any such modifications to this Privacy Policy on our Site. We suggest that you periodically consult this Privacy Policy. Your continued use of the Site after any such changes constitutes your acceptance of this Privacy Policy, as revised.

Please note that this Privacy Policy only applies to personal information we collect from you while you are using our Site, and does not apply to any personal information collected by any third party, even if we have included links to third-party websites, plug-ins or applications in our Site. You shall review carefully the privacy policies or procedures of the third parties if you access to any websites, services or applications of any third parties, whether or not through links in our Site. We expressly disclaim any responsibility or liability as to the compliance of such third parties with applicable privacy laws in their jurisdiction.

Privacy Policy Summary.

This Privacy Policy contains the following subjects pursuant to the applicable legislation in Cayman Islands and to the extent applicable, the laws of California, the European Economic Area (“EEU”) and the United Kingdom (“UK”).

  • What Personal Information We Collect
  • How We Use Personal Information
  • How We Share Personal Information
  • Your Choices

What Personal Information We Collect.

Personal information is information about an identifiable individual (“Personal Information”). Company collects Personal Information when you voluntarily provide it through our Site or when you provide it to us through other means. For example, we may collect Personal Information when you:

  • contact us through e-mail, telephone, mail or other correspondence;
  • register for a service we provide;
  • register or connect your blockchain wallet with the Site;
  • register to undertake transactions on our Site; or
  • register to receive our newsletter.

The Personal Information we may collect will depend on the service you request and may include:

  • your full name or any information we can reasonably use to directly or indirectly identify you;
  • your blockchain address or third-party wallet account;
  • contact information, such as your address, telephone number, or e-mail address;
  • information and content you provide;
  • the people, groups, networks you are connected to;
  • transactions you made on the Site;
  • your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details; or
  • any other Personal Information that you choose to submit to us.

We may also collect such non-personal information that does not directly or indirectly reflect your identity such as demographic information or aggregated information, as well as information regarding clickstream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, etc. To improve the quality of our service on the Site, we may conduct research and analysis based on the Personal Information we collected and generate statistics we can use to help guide our practice.

How Company Collects Information Through Technological Means.

When you visit our Site, we may collect information that is automatically sent to us by your web browser. This information may include:

  • information about your time zone setting, equipment and operation system you use or internet connection;
  • your domain name; and
  • your numerical IP address.

We may also collect other information, such as the type of browser you use, which pages you view, and the files you request.

We use this information to:

  • conduct data analysis to improve customer experience;
  • better understand how visitors use our Site; and
  • to improve our Site to better meet your needs.

The amount of information that is sent by your web browser depends on the browser and settings you use. Please refer to the instructions provided by your browser if you want to learn more about what information it sends to websites you visit or how you may change or restrict this.

Company may use “cookies” and other similar devices on this Site to enhance functionality. These devices may track information which includes but is not limited to (i) IP address, (ii) the type of web browser and operating system used (iii) the pages of the Site visited; and (iv) any further information collected by these tools. We use this information to improve our Site and the service we dedicate to provide to our users.

If you wish to disable cookies, refer to your browser help menu to learn how.

In addition to above, we also retrieve data from activity that is publicly visible and/or accessible on blockchains. This may include blockchain addresses and information regarding the crypto assets in wallets.

How Company Uses and Discloses Personal Information.

The Personal Information we collect may be used by Company for the purposes for the following purposes, or for other purposes that are disclosed to you and to which you consent.

  • respond to your inquiries;
  • supply you with requested products or services;
  • facilitate the transactions you made on Site;
  • send you informational or promotional communication;
  • fulfill the purpose for which you provided the information;
  • protecting the security and integrity of the services on Site; improving the services;
  • carry out other purposes that are disclosed to you and to which you consent;
  • verify accounts and activities to stop spam and other bad behaviors on the Site;
  • process complaints or investigations in relation to any content you provided or transactions you undertaken on the Site;
  • carry out any other purpose permitted or required by law.

We may transfer Personal Information to third party service providers that assist us with carrying out these purposes.

Company reserves the right to transfer Personal Information in the event that we merge with or are acquired by a third party. We also may disclose your Personal Information for any other purpose permitted by law or to which you consent.

We may also disclose your Personal Information as required by law, regulation, rule or valid court order or pursuant to any requirement, request or process of any legal, regulatory, governmental, or supervisory authority; to enforce our rights or interests under the applicable terms and conditions of our services or products provided by us to you; or to protect the rights, property, or interests of our clients or other users.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.

Your Choices.

We have employed the following measures to allow you make your choices as to the provision of Personal Information to us:

  • You can log out the Site and refuse to conduct any dealings on our Site if you do not wish to provide any Personal Information to us;
  • You can set your browser to disable or refuse all or some browser cookies;
  • You can choose to use only part of the functions or services provided by the Site and avoid those functions or services which require additional Personal Information from you; and
  • You can contact us via the contact information at the bottom of this Policy if you do not wish to receive any correspondence from us.

How We Protect Personal Information.

The security of your Personal Information is important to us. We help protect your Personal Information in our control by maintaining physical, organizational and technological safeguards. Personal Information may be accessed by persons within our organization who require such access to carry out the purposes described in this Privacy Policy, or such other purposes as permitted or required by law.

We retain Personal Information that we collect only as long as necessary for the purposes for which it was collected or to meet legal requirements. We destroy Personal Information when it is no longer needed.

It is important to understand that no security measures are absolute. We cannot guarantee the safety of any information you provide to us.

We May Transfer Personal Information to Other Countries.

Please be aware that Personal Information collected through the Site may come from different jurisdictions and be transferred to, processed, stored, and used in the United States, EEA, the UK, Cayman Islands and any other jurisdictions where the Company or its affiliates maintain operations or engage service providers. Data protection laws in these jurisdictions may be different from those of your country of residence. However, we will take steps to ensure that the data we collect is processed according to the provisions of this Privacy Policy and the requirements of applicable law wherever the data is located, including the transfer of data in accordance with a valid data transfer mechanism.

Your use of the Site or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in EU, EEA, UK, Cayman Islands and other jurisdictions as set out in this Privacy Policy and to the extent permitted under applicable laws.

Children Information.

The Site and all information thereon are intended for general audiences and are not directed at children. To use the Site, you must legally be able to enter into an agreement for so doing. We do not knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information in violation of COPPA, please contact us via our contact email in section “How to Contact Us” and we will remove the personal information in accordance with COPPA.

Accessing and Correcting your Personal Information.

You have a right to access your Personal Information and to request a correction to it if you believe it is inaccurate. If you have submitted Personal Information and would like to have access to it, or if you would like to have it corrected, please contact us using the contact information below. We may require you verify your identity before allowing you to access your personal information.

How to Contact Us.

If you have any questions regarding this Privacy Policy, to submit a complaint, or to access or correct your information, or to withdraw your consent to this Privacy Policy, please contact our Privacy Officer via the contact information below:

Privacy Officer

[email protected]

Additional Disclosures for California Residents.

These additional provisions under this section apply only to California residents. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete, and opt-out, and requires businesses collecting or disclosing personal information to provide notices and the means to exercise consumer rights.

A. Information We Collect and Share.

For details on the information we may collect, please review the section “What Personal Information We Collect”. We may collect and use these personal information for the business purposes described in the section “How Company Uses and Discloses Personal Information” above.

We do not “sell” personal information as defined under the CCPA. Please review the “How Company Uses and Discloses Personal Information” section above as to how we share information.

B. Right to Know and Delete.

You have the right to know certain details about our data practices within the past twelve (12) months. In particular, you may request the following from us:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information was collected;
  • The categories of personal information about you we disclosed for a business purpose;
  • The categories of third parties to whom the personal information was disclosed for a business purpose;
  • The business or commercial purpose for collecting or selling the personal information; and
  • The specific pieces of personal information we have collected about you.

In addition, you have the right to delete the personal information we have collected from you.

To exercise any of these rights, please submit a request by emailing us via our contact email in section “How to Contact Us”. In the request, please specify what specific information you wish to delete from our file. Please be as specific as possible to help us identify and action on your request in an expeditious manner. We will confirm receipt of your request within ten (10) days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

Notwithstanding the foregoing, we cannot edit or delete information that is stored on a particular blockchain as we do not have custody or control over any blockchains. This information includes all transaction data related to your interaction with Crossbell on the blockchain or your minting of any Character or content into NFT on Crossbell.

C. Authorized Agent.

You may designate an authorized agent to submit requests on your behalf; however, we may require written proof of the agent’s permission to act on your behalf and verify your identity directly.

D. Right of Non-Discrimination.

You have a right of non-discrimination for the exercise of any of your privacy rights guaranteed by law, such as the right to access, delete, or opt-out of the sale of your personal information.

E. California Shine the Light Request.

Users who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write to us at the email set out in the “How to Contact Us” section above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once per calendar year.

Additional Disclosures for Data Subjects in the European Economic Area, the United Kingdom and Cayman Islands.

The following provisions apply only to residents of EEA, UK and Cayman Islands.

A. Roles.

The General Data Protection Regulations in the European Economic Area and the United Kingdom (“GDPR”) and the Data Protection Act (“DPA”) of Cayman Islands distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). We act as a controller with respect to personal data collected as you interact with the Site.

B. Lawful Basis for Processing.

The GDPR and DPA require a “lawful basis” for processing personal data. Our lawful bases include where: (i) you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners; (ii) processing is necessary for the performance of a contract with you; (iii) processing is necessary for compliance with a legal obligation; or (iv) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third parties subject to appropriate or suitable safeguards, such as standard contractual clauses.

C. Your Data Subject Rights.

If you are a user in the European Economic Area, the United Kingdom or Cayman Islands, you maintain certain rights under the GDPR or DPA, as applicable. These rights include but not limited to the right to (i) request access and obtain a copy of your personal data; (ii) request rectification or erasure of your personal data; (iii) object to or restrict the processing of your personal data; and (iv) request portability of your personal data. Additionally, if we have collected and processed your personal data with your consent, you have the right to withdraw your consent at any time.

Notwithstanding the foregoing, we cannot edit or delete information that is stored on a particular blockchain as we do not have custody or control over any blockchains. This information includes all transaction data related to your interaction with Crossbell on the blockchain or your minting of Characters or content into NFT on Crossbell.

To exercise any of these rights, please contact us via our email or postal address listed in the “How to Contact Us” section above and specify which right you are seeking to exercise. We will respond to your request within thirty (30) days. We may require specific information from you to help us confirm your identity and process your request. Please note that we retain information as necessary to fulfill the purpose for which it was collected and may continue to retain and use information even after a data subject request in accordance with our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

If you have any issues with our compliance, please contact us as set out in the “How to Contact Us” section above. You also reserve the right to lodge a complaint with the data protection regulator in your jurisdiction.

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