Privacy Policy

Thank you for your interest in this Privacy Policy! At TR3ASURE, we take the protection of your Personal Data very seriously.

This Privacy Policy serves to inform you about the processing of your personal data when you use our website www.tr3asure.xyz (“Website”) and services. We will only use your personal data in accordance with the applicable data protection laws, in particular the British Virgin Islands Data Protection Act (“DPA”) and, where applicable, the EU General Data Protection Regulation (“GDPR”).

As such, this Policy sets out how personal data is managed and dealt with in order to ensure that the obligation to fulfil individuals' reasonable expectations of privacy is applied and followed and that the responsibilities established under the DPA and GDPR are complied with.

All the definitions used in this Privacy Policy shall have the same meaning as in our Terms of NFT Sale and Use unless this Policy sets a different meaning.

  • Responsibility for data processing

    We will act as a data controller in relation to personal data about you that may be either provided by you or collected by us. As a data controller, we will solely determine the purposes and means of the processing of your personal data. The entity responsible for data processing in accordance with the provisions of the DPA and GDPR is:

    • TR3ASURE Ltd.
    • Intershore Chambers,
    • Road Town,
    • Tortola,
    • British Virgin Islands
    • (hereinafter “TR3ASURE Ltd”, “we”, “us” or “our”)
    • For any inquiries about the usage and processing of your personal data please email us at
    • support@tr3asure.xyz.

  • General information and mandatory disclosures

    What is personal data?

    Generally, personal data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, social media identifier, email address or messengers identifiers, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not personal data. This includes, for example, the number of users of a website.

    Please note that not all the information you provide to us is personally identifiable information according to applicable data protection laws.

    It is your sole decision whether to provide us with the requested information or not. However, if you choose to withhold the requested information, we may not be able to provide you with access to the Website or the possibility to use our services. Depending upon the activity, some of the information that we ask you to provide is identified as mandatory and some as optional. Please do not supply any other person's personal data to us, unless we prompt you to do so.

    Our principles of data processing

    Personal data will only be used in the specific context of your customer relationship with us and to the extent permitted by law or on the basis of your prior express consent. In particular, we are committed to the following key principles:

    • We protect your privacy and aim to provide you with a service that is tailored to your needs.
    • Personal data is collected for specific purposes based on your consent or a legitimate interest when you contact us.
    • You have the right to information and access to your personal data at any time and may request its correction or deletion.
    • We do not sell your personal data to third parties.
    • We take all reasonable measures to ensure the security and protection of your data from misuse.
    • Personal data are processed by us only as necessary and for the purpose of providing the services offered.

    General processing

    Our processing means any operation or set of operations which is performed on personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, support, maintenance, etc.

    We have implemented measures designed to secure your personal data from accidental loss and unauthorised access, use, alteration, and disclosure.

  • Specific information on how we use your personal data

    We never collect your wallet’s private keys or passphrases and never have access to your wallet because none of your private keys ever leave the local storage of your device.

    Simplified disclosure

    Simply put (more detailed provisions follow below), we use information held, including personal data, in the following manner:

    • to ensure that content from the Website is presented in the most effective manner for you and for your device;
    • to provide you with information, TR3ASURE NFTs or services that you request from us, and to otherwise carry out our obligations arising from any contracts entered into between you and us;
    • to provide you with information, products or services which we feel may interest you, where you have consented to be contacted for such purposes;
    • to allow you to participate in interactive features of our service, when you choose to do so;
    • to notify you about changes to our services;
    • to investigate any complaints relating to the use of the Website or any suspected unlawful activities;
    • complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; and
    • any other purposes for which you have provided the information.

    Usage Data

    We may process information about your use of the Website (“usage data”). The usage data may include:

    • your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and navigation paths, as well as information about the timing, frequency and pattern of your use;
    • your device number, device id or unique identifier, device type, and unique device token, operating system and applications used, application crash-data, application version;
    • cookies.

    The source of the usage data is our analytics tracking system and your usage of the Website. This usage data may be processed for the purposes of analysing the use of the Website and to keep you signed in at the Website. The legal basis for this processing is your consent and our legitimate interest, namely monitoring and improving the Website and our services.

    Account data

    We may process your account data (“account data”). The account data includes only the public wallet address of your connected wallet and transactions you carry out through the Website.

    The source of the account data is you. The account data may be processed for the purposes of providing you access to the Website, our related services, the ability to purchase TR3ASURE NFTs, ensuring the security of the Website and related services and communicating with you. The legal basis for this processing is a performance of an agreement between you and us and/or taking steps, at your request, to enter into such an agreement.

    Customer relationship data

    We may process information contained in or relating to any communication that you send to us, or relating to our customer relationships with you (“customer relationship data”). The customer relationship data may include your name, your nickname, your contact details you provided us with (phone number, social media identifier, email address or messengers identifiers you use to communicate with us) and information contained in communications between us and you.

    The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, customer support, quality assurance of our customer support and communication with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is a performance of an agreement between you and us and/or taking steps, at your request, to enter into such an agreement and our legitimate interest, namely the proper management of our customer relationships and administration of the Website.

    Processing of personal data for legal purposes

    We may process any of your personal data identified in this Policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interest, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

    We may process any of your personal data identified in this Policy where necessary for the purposes of managing risks or obtaining professional advice. The legal basis for this processing is our legitimate interest, namely the proper protection of our business against risks.

    We may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another individual.

    Processing of personal data for marketing purposes

    We may process your personal data identified in this Policy to keep you informed about our new products, product upgrades, special offers, webinars, events and promotions that may be of interest to you, to send you updates regarding collectibles or services you have shown interest in or provide further information related to the topic you requested, or to get your consent to further contacting you regarding any other services you might be interested in. The legal basis for this processing is our legitimate interest, namely the development and conducting of our business.

    We may use your personal data to send you promotional emails and/or newsletters when you have clearly consented to receive such communications. The legal basis for this processing is your consent to receive promotional communications from us.

    We may use aggregate, non-identifying statistical data for statistical analysis, marketing, or similar promotional purposes to help improve our offerings to you or to improve your browsing experience by personalizing the Website.

    Automated decision making

    Automated decision making is not used.

    Processing of special categories of data

    No special categories of data are processed.

    Withdrawal of consent

    You may withdraw your consent and request us to stop using and/or disclosing your personal data. Should you withdraw your consent to the collection, use or disclosure of your personal data, it may impact our ability to proceed with your transactions, agreements, or interactions with us when our processing is solely based on your consent (for example, for processing of your personal data for the purpose of performance and agreement with you we do not need your consent).

    Prior to you exercising your choice to withdraw your consent, we will inform you of the consequences of the withdrawal of your consent.

    Please note that your withdrawal of consent will not prevent us from exercising our legal rights (including any remedies) or undertaking any steps as we may be entitled to at law.

  • Disclosing your personal data

    We will not disclose or otherwise distribute your personal data to third parties unless this is necessary for the performance of an agreement with you, performance of our services, you have consented to the disclosure, or the disclosure of data is permitted by relevant legal provisions.

    We are entitled to outsource the processing of your personal data in whole or in part to external service providers acting as processors for us within the framework of the DPA and GDPR (where applicable). External service providers support us, for example, in the technical operation and support of the Website, data management, the provision and performance of services, marketing, as well as the implementation and fulfilment of reporting obligations. The service providers commissioned by us process your data exclusively in accordance with our instructions. Nonetheless, we remain responsible for the protection of your data, which is ensured by strict contractual regulations, technical and organisational measures, and additional controls by us.

    Personal data may also be disclosed to third parties if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to fulfil our legitimate interests.

  • Retaining and deleting your personal data

    We only retain your personal data for as long as it is necessary for us to use your data as described above or to comply with our legal obligations and legitimate interests. For instance, we may retain your data as necessary to meet our legal obligations, such as for tax and accounting purposes. Insofar as statutory retention obligations must be observed, the storage period for certain data may be up to 10 years, irrespective of the processing purposes.

    We will store your personal data that is used to send you promotional e-mails and/or newsletters or used in relation to your support tickets. Such information will be stored and processed solely for this purpose until you withdraw your consent, where applicable, or unsubscribe from newsletters, but not longer than for 4 years after your last interaction with us.

    Otherwise, we either delete or anonymise the personal data collected. In case personal data was transferred to backup storage and, therefore, cannot be deleted, we continue to store it securely, but do not use it for any purpose. In all the other cases, we proceed with the deletion of personal data.

  • Third parties

    The Website may contain links to any other websites or services. Please note that we are not responsible for the privacy practices or the content of such websites or services, and you should review the privacy policy of each such website or service to make sure you are comfortable with it before providing any personal data.

    Also in order to purchase a TR3ASURE NFT, you may need to connect a valid blockchain wallet (for example, MetaMask or WalletConnect). We would like to point out that we are not responsible for any processing of personal data when connecting your blockchain wallet.

    To provide the Website, we use a web hosting service, which processes the data mentioned below and all other data that is processed in connection with the operation of our website on our behalf. Our website is hosted using the services of DigitalOcean, LLC. You may find DigitalOcean's privacy policy via the link: https://www.digitalocean.com/legal/privacy-policy.

  • Cookies

    As with many other websites in the world, the Website uses cookies. A cookie is a small file on your device with a string of letters and numbers which serves as a unique identifier. Sometimes cookies can also be used to store your personal preferences on websites. When you open the Website for the first time, cookies are created on your device. When you open it next time, cookies are sent back to us, thus letting us know you’ve already been there. We don’t create cookies ourselves, but we use third-party providers who do it for us.

    We generally may use cookies for the following purposes:

    • authentication – we use cookies to identify you when you visit the Website and as you navigate through the Website;
    • status – we use cookies to help us to determine if your blockchain wallet is connected to the Website;
    • security – we use cookies as an element of the security measures used to protect the Website and our services generally;
    • analysis – we use cookies to help us to analyse the use and performance of the Website and services; and
    • cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

    We may use analytics packages from trusted third parties to constantly improve your experience of using the Website and related services. Our trusted partners help us serve advertising and/or analytics and may place cookies on your device.

  • Data breaches/notification

    Upon becoming aware of a data breach, we will take all necessary steps to notify affected individuals whose personal data may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after the breach was discovered.

  • Personal data and children

    Our services are aimed at people aged 18 and over. We will not knowingly collect, use, or disclose personal data from minors under the age of 18 without first obtaining consent from a legal guardian through direct offline contact.

  • Your rights

    You may have several rights under applicable data privacy laws:

    Right of access

    You have the right to obtain confirmation if your personal data is being processed by us. If that is the case, you can access your personal data and the following information: (i) the purposes of the processing; (ii) the categories of personal data; (iii) to whom the personal data has been or will be disclosed; (iv) the envisaged period for which the personal data will be stored, or the criteria used to determine that period.

    If you would like to have a copy of your personal data from us, we will provide it if (i) you prove your identity, (ii) it will not adversely affect the rights and freedoms of others. The first copy will be provided for free, for any further copies we may charge a reasonable fee based on administrative costs.

    Right to rectification

    You have the right to demand that we correct without undue delay your personal data which we have in our systems if it is inaccurate or incomplete.

    Right to erasure (“right to be forgotten”)

    You have the right to demand that we erase your personal data, and we shall erase it without undue delay where one of the following grounds applies: (i) this personal data is no longer necessary in relation to the purposes for which it was processed; (ii) you withdraw consent on which the processing is based, and where there is no other legal ground for the processing; (iii) you object to the processing and there are no overriding legitimate grounds; (iv) your personal data has been unlawfully processed; (v) your personal data has to be erased for compliance with a legal obligation.

    Right to restrict processing

    You have the right to restrict us in the ability of processing your information where one of the following applies: (i) you contest the accuracy of your personal data and we are verifying it; (ii) the processing is unlawful and you want to restrict it instead of erasure; (iii) we no longer need your personal data, but you need it for establishment, exercise or defense of legal claims; (iv) you have objected to processing and we are verifying whether legitimate grounds override your request.

    Right to object

    You have the right to object to the processing of your personal data based on our legitimate interests. We shall no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing or for the establishment, exercise or defense of legal claims.

    Where personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing.

    Right to withdraw consent

    You have the right to withdraw your consent for processing of your personal data at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

  • Changes to this Privacy Policy

    We reserve the right to adapt the Privacy Policy with effect for the future, in particular in the event of further development of the Website, the use of new technologies or changes to the legal basis or the relevant case law.

    If you have any questions or comments about our Privacy Policy or wish to exercise your rights under applicable laws, please contact us.

Last Updated on 3 April 2023