HAON PTE. LTD. and its affiliates (“we”, “our”, “us”, or “the Company”) prioritize the privacy and security of the information we collect from our users. This Privacy Policy outlines our commitment to protect your personal information and informs you about our data collection, use, and sharing practices. It applies to all interactions with our NUMINE platform, which includes our website, app, the NUMINE wallet, NFT Market, Games, and any associated online communities (collectively, the “Services”).

We encourage you to read this Privacy Policy carefully, alongside any other privacy notices we may provide on specific occasions. This ensures you are fully informed about how we use your information and the rights you have under data protection laws.

By using our Service, you acknowledge you have read, understood, and agreed to the collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service. Should you have any questions or concerns regarding this policy or your personal information, please do not hesitate to contact us at contact@numine.io

• Definitions and key terms

To help explain things as clearly as possible in this Privacy Policy, every time any of these terms are referenced, are strictly defined as:

1. 1. Cookie: small amount of data generated by a website and saved by your web browser. It is used to identify your browser, provide analytics, remember information about you such as your language preference or login information.
2. 2. Company: when this policy mentions “Company,” “we,” “us,” or “our,” it refers to HAON PTE. LTD., (111, SOMERSET ROAD, #06-01H, 111 SOMERSET, SINGAPORE 238164), that is responsible for your information under this Privacy Policy.
3. 3. Device: any internet connected device such as a phone, tablet, computer or any other device that can be used to visit NUMINE and use the services.
4. 4. IP address: Every device connected to the Internet is assigned a number known as an Internet protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the Internet.
5. 5. Personal Data: any information that directly, indirectly, or in connection with other information allows for the identification or identifiability of a natural person.
6. 6. Service: refers to the service provided by NUMINE as described in the relative terms (if available) and on this platform.
7. 7. Third-party service: refers to advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose products or services we think may interest you.
8. 8. User: a person or entity that is registered with NUMINE to use the Services.

• COLLECTION OF PERSONAL DATA

“Personal Data” refers to any information that directly, indirectly, or in connection with other information allows for the identification or identifiability of a natural person.

Information we collect from you may include:

• · Contact information such as phone numbers and email addresses.
• · Registration details such as authentication tokens provided by third-party platforms (e.g., Google, Apple, Facebook, or WeChat) for signing up to the NUMINE wallet and accessing Games through their respective mobile apps, along with your NUMINE wallet ID, address, encrypted key, and technical information.
• · Automatically collected data such as Google Analytics cookies (see our Cookie Policy for more details).
• · Information necessary for handling inquiries and requests from you, such as your in-game ID or nickname, and details related to the issue you are contacting us about.
• · In-game activity, such as quests and games completed, NFT transactions.
• · Information required for registering as a NUMINE NFT creator or managing posts on the NUMINE forum.
• · Crypto wallet address, including related data used to detect cryptocurrency and NFT holdings.
• · IP address (we may also derive your approximate location from your IP address).

To provide the requested services, we collect the aforementioned categories of information directly from you or from other sources, including users of our Services and third-party services and organizations (e.g., Google, Apple, Facebook, WeChat). Please refer to Appendix II for further details on personal data collected from third parties. Without this information, we are unable to provide you with all requested services, and any variances in services are contingent upon your information. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

• USE OF PERSONAL DATA

We will use your personal data for the following purposes:

1. 1. Providing service functionality and handling requests:

   • · Managing access to registered accounts, processing transactions, and providing related benefits, special promotions, or customer support.
   • · Providing administrative information such as updates to terms, conditions, and policies.
   • · Complying with applicable laws and regulations, including legal obligations, dispute resolution, enforcement of contractual agreements, and establishment, exercise, or defense of legal claims.
   • · Sending electronic correspondence related to inquiries or service use.

2. 2. Providing marketing materials and facilitating social sharing:

   • · Sending marketing-related emails containing service information, new products, and company updates.
   • · Facilitating social sharing features as per user preference.
   • · These activities are conducted with user consent or based on legitimate interests.

3. 3. Analyzing personal information for business reporting and personalized services:

   • · Analyzing user preferences to generate aggregated trend reports on digital content usage and improve services.
   • · Understanding user interests to personalize interactions and provide tailored information and offers.
   • · Providing content through the service tailored to user interests.
   • · These activities are conducted based on legitimate interests and, where required by law, with user consent.

4. 4. Aggregating and/or anonymizing personal information:

   • · Aggregating and/or anonymizing personal information to generate non-personal data for various purposes.
   • · Conducting business activities such as data analysis, debugging, audits, fraud prevention, and product development.
   • · These activities are conducted to manage contractual relationships, complying with legal obligations, and pursuing legitimate interests.

5. 5. Additional purposes:

   • · Supporting service functionality, maintaining user accounts, and providing forum and community features.
   • · Improving service quality through maintenance, troubleshooting, data analytics, and testing.
   • · Ensuring service and user safety, detecting and responding to fraud, abuse, security risks, and technical issues.

We process your personal data based on legal grounds as described in Appendix I.

• DISCLOSURE OF PERSONAL DATA

We may disclose your personal information to third parties under these circumstances:

1. 1. Disclosure to Service Providers and External Data Controllers:

   • · We may engage third-party vendors and service providers (referred to as “data processors”) to handle your personal data for the purposes described previously. These data processors are obligated to follow our instructions according to this document and adhere to strict confidentiality and security measures.
   • · We may disclose your personal information to external data controllers for processing in alignment with the outlined purposes. For detailed information regarding the disclosure of personal data to external controllers, refer to Appendix II.

2. 2. Disclosure Related to Business Transactions:

   • · Your personal information may be disclosed in the context of significant business transactions, such as the sale of a website, mergers, consolidations, sales of assets, initial public offerings, or in the unlikely scenario of bankruptcy.

3. 3. Legal Disclosure:

   • · Your personal information may be disclosed in compliance with legal obligations, including responding to subpoenas or court orders.

4. 4. Disclosure with your consent:

   • · We may share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Sites, you instruct us to take a specific action with respect to your personal information, or you opt into third-party marketing communications.

Our platform enables you to post and share messages and content with others. Should you participate in public forums within the Services, be mindful that any information disclosed can be accessed, collected, or used by others in these spaces. We advise caution in revealing information in these public forums. We are not liable for information you decide to share in these public areas.
If your personal data is to be transferred outside of the EU and the European Economic Area (EEA) to a country not deemed by the European Commission to have adequate data protection, we will take necessary steps to ensure your personal data is still protected and secured in line with applicable data protection and privacy laws. This includes employing safeguards such as data transfer agreements that incorporate the European Commission's Standard Contractual Clauses, ensuring an adequate level of data protection.

• DATA SECURITY

In our commitment to safeguarding your personal data, we implement comprehensive organizational, technical, and administrative measures designed to protect your personal data within our organization. Despite our rigorous efforts, we recognize that no data transmission or storage system is infallible, and 100% security cannot be assured. Should you have any concerns regarding the security of your interactions with us, it's imperative that you contact us without delay, following the guidelines outlined in the “Contacting Us” section below.

To prevent unauthorized access, use, loss, alteration, or disclosure of your personal data, we have established robust security protocols. Access to your personal data is strictly confined to employees, agents, contractors, and other third parties who require this information to perform their job functions. These individuals are obligated to maintain the confidentiality of your data and are instructed to handle it in compliance with our stringent privacy standards.

Furthermore, we have developed procedures to promptly address any suspected data security breaches. In the event of a breach, we are committed to notifying you and any relevant regulatory authorities, as required by law. Our proactive approach to data security ensures that we take every possible measure to protect your personal data against unauthorized access or disclosure, thereby maintaining the trust you place in us.

• RETENTION

In the Retention section of our Privacy Policy, it's specified that your Personal Information will be stored only for the period necessary or as authorized, based on the initial purpose of collection and in alignment with legal requirements.

Key considerations that guide the duration of retention for your information are:
The duration of our ongoing engagement with you, including the provision of our Services (this extends for the period you hold an account with us or as long as you utilize our Services);
Any legal mandates we are obliged to adhere to (for example, the law may dictate that we retain records of your interactions for a predetermined length of time before they are eligible for deletion); and The prudence of maintaining records given our legal standing (considerations might include, but are not limited to, applicable statutes of limitations, involvement in litigation, or being subject to regulatory scrutiny).

This approach ensures that we do not retain your Personal Information longer than necessary, balancing our service commitments to you with legal compliance and risk management.

• Cookies

NUMINE uses "Cookies" to identify the areas of our website/app that you have visited. A Cookie is a small piece of data stored on your device by your web browser. We use Cookies to enhance the performance and functionality of our website/app but are non-essential to their use. However, without these cookies, certain functionality like videos may become unavailable or you would be required to enter your login details every time you visit the website/app as we would not be able to remember that you had logged in previously. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our website/app correctly or at all. We never place Personally Identifiable Information in Cookies.

We use Cookies to enhance the performance and functionality of our platform but are non-essential to their use. However, without these cookies, certain functionality like videos may become unavailable or you would be required to enter your login details every time you visit the platform as we would not be able to remember that you had logged in previously.

• Blocking cookies and similar technologies

Wherever you're located you may also set your browser to block cookies and similar technologies, but this action may block our essential cookies and prevent our website/app from functioning properly, and you may not be able to fully utilize all of its features and services. You should also be aware that you may also lose some saved information (e.g., saved login details, site preferences) if you block cookies on your browser. Different browsers make different controls available to you. Disabling a cookie or category of cookie does not delete the cookie from your browser, you will need to do this yourself from within your browser; you should visit your browser's help menu for more information.

• USE OF SERVICES BY MINORS

Our Services are not intended for individuals under the age of 18. We do not knowingly collect or sell information from children without parental consent or as permitted by law.

• INTERNATIONAL DATA TRANSFER AND JURISDICTION

We may store and process your personal data in any country where we operate or utilize service providers. By utilizing our services, you acknowledge the transfer of your data to countries outside your own, including the United States, which may follow different data protection laws than those in your country. Under certain conditions, legal, law enforcement, regulatory, or security authorities in these countries might have the right to access your personal data.

EEA AND UK DATA TRANSFER DETAILS: The European Commission recognizes some countries outside the EEA as having adequate data protection levels in line with EEA norms (a complete list of these countries is available at: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en). The UK similarly acknowledges the EEA and these specified countries for their data protection standards. For data transfers from the EEA or UK to countries not deemed adequate by the European Commission or UK authorities, we implement safeguards like standard contractual clauses approved by the authorities to ensure your personal data's protection. For details on these safeguards, please reach out to us as outlined in the “Contacting Us” section.

• SENSITIVE INFORMATION

We request that you refrain from sending or disclosing any sensitive personal data to us (such as social security numbers, racial or ethnic origins, political opinions, religious beliefs, health information, biometric or genetic data, criminal history, or trade union membership) through our Services or other means, unless explicitly requested by us.

• UPDATES TO THIS PRIVACY POLICY

We may change this privacy policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make any changes, we will change the Last Updated date above.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the changes to the Sites (or as otherwise indicated at the time of posting). In all cases, your continued use of the Sites or Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

• CONTACTING US

HAON PTE.LTD., located at 111, SOMERSET ROAD, #06-01H, 111 SOMERSET, SINGAPORE, is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at contact@numine.io.

• ADDITIONAL INFORMATION REGARDING THE EEA

If you suspect a violation of data protection laws, you are entitled to submit a complaint to the data protection authority in your place of usual residence, your workplace, or the location of the alleged infringement. For a list of data protection authorities within the European Economic Area (EEA), please refer to: https://edpb.europa.eu/about-edpb/board/members_en.

• ADDITIONAL INFORMATION REGARDING CALIFORNIA

In accordance with the California Consumer Privacy Act of 2018 ("CCPA"), we provide detailed information on the categories of Personal Information that we collect, use, and disclose regarding California residents. It is important to note that this section does not apply to personal information collected about job applicants, employees, contractors, proprietors, directors, or officers in relation to their current, former, or potential roles within our organization.

• INFORMATION CHOICES AND CHANGES

Accessing, Updating, Correcting, and Deleting your Information
You may access information that you have voluntarily provided through your account on the Services, and to review, correct, or delete it by sending a request to contact@numine.io. You can request to change contact choices, opt-out of our sharing with others, and update your personal information and preferences.

• Collection and Disclosure of Personal Information

The following chart details which categories of Personal Information about California residents we plan to collect, as well as which categories of Personal Information we have collected and disclosed for our operational business purposes in the preceding 12 months.

We do not “sell” and have not “sold” Personal Information for purposes of the CCPA in the last 12 months. For example, and without limiting the foregoing, we do not sell the Personal Information of minors under 16 years of age.

· SOURCES OF PERSONAL INFORMATION

As previously mentioned, we acquire various types of Personal Data directly from you.

• USE OF PERSONAL INFORMATION

In line with the prior description, we utilize these types of Personal Data to facilitate the operation, management, and upkeep of our business activities, ensuring the delivery of our products and services, and achieving our business aims, including leveraging Personal Data to:

• · Address your requests and answer your questions
• · Enhance, refine, fix, supply, and uphold our products and services;
• · Customize, promote, and market our offerings;
• · Enable your participation in draws, giveaways, competitions, or other promotional events;
• · Execute studies, analytics, data evaluations, compilations, and privacy measures;
• · Preserve our facilities and records, and implement measures for quality and safety verification;
• · Undertake surveillance and management of risks and security, alongside fraud detection and prevention;
• · Carry out identity checks, financial accounting, audits, and other in-house operations such as investigations and documentation;
• · Facilitate business activities such as mergers, partnerships, or acquisitions;
• · Adhere to legal statutes, procedural requirements, and internal guidelines, while asserting and safeguarding against legal actions.

• INDIVIDUAL RIGHTS AND REQUESTS

If you're a resident of California, you're entitled to ask us to:
Provide you with information for the 12 months before your request, including:

• · The types of Personal Information we've gathered about you and where we got it;
• · The exact Personal Information we've collected;
• · The reason we collected your Personal Information (if it applies);
• · The types of Personal Information we've shared or revealed about you, and who we've shared it with or revealed it to (if it applies).

Remove any Personal Information about you that we have collected.
To request the information or deletion mentioned, please reach out to us at contact@numine.io. We will check and respond to your request as the law requires, considering the nature and confidentiality of the Personal Information involved. We might need to ask for more details from you, such as your email or wallet address, to confirm it's really you making the request and guard against fraudulent claims. Should you ask for your Personal Information to be deleted, we might confirm your request before proceeding.
Exercising your rights under the CCPA should not lead to any illegal discrimination against you.

APPENDIX I

Purposes for Processing USER Data

APPENDIX II

Information Collected from third parties