Last revised: 30/05/2023
on social networks, but also more generally in the context of your relations with us, and how we treat them (see information relating to the methods of collection, processing and use of your personal data staff).
Mainbot, a French société par actions simplifiée, registered under number 824 611 800 with the Trade and Companies Register of Paris, whose registered office is located at 33 Avenue du Maine,Tour Maine, Montparnasse, 45ème étage, 75755 Paris Cedex 15 (hereinafter
“Company” or “MAINBOT”).
The Company operates the website accessible to the public at the following url address: https://www.winkyverse.io (hereinafter the “Site”).
This Site aims to:
• provide users with information enabling them to discover the activity and services offered by the Company, as well as its news (events, publications, etc.);
• offer functionalities and / or information allowing users to contact the Company and present the services offered by the Company, the projects carried out by the latter and to come, or the team working on these projects;
• provide users access to the Platform and various associated services (hereinafter the “Services”) as detailed in our general conditions https://www.winkyverse.io/terms.
During your navigation and your interactions on the Site, on the pages administered by the Company on social networks or, in general during your interactions or exchanges with the Company, the latter may be required to collect and process Data of a non-personal and personal nature
In this context, the Company applies namely the principles defined by the legal and regulatory provisions on the protection of personal data, in particular in Regulation (EU) 2016/679 of April 27, 2016 on the protection of natural persons at with regard to the Processing of Personal Data ("RGPD") or even Law 78-17 of 6 January 1978 relating to computers, files and freedoms (known as the "Data Protection Act") and its decrees.
2. Processed Personal Data
The Personal Data processed in the context of the Services offered by MAINBOT are:
• For participants in the NFTs sale: crypto wallet (public key) only.
• For users, through a know your customer process (“KYC”):
o last name,
o first name,
o email address.
The collection of Personal Data is limited to the strict minimum. Consequently, only relevant, adequate, and limited information is collected in relation to the purposes for which it is processed.
Non-personal data (such as address of your wallet or its content) can also be collected in relation to the purposes for which it is processed.
3. Purposes of the processes
The purposes of this Processing of Personal Data is to allow the Users to benefit from the Services offered by MAINBOT and for which the Processing of Personal Data is essential. Thus, the collection and Processing of Personal Data by MAINBOT responds to specified,
explicit and legitimate purposes, namely:
• For participants in the NFTs sale and Users:
o account management,
o relationship follow-up,
o information and invitations to events,
o prospecting and animation.
4. Legal basis of the Processing
The collection and Processing of Personal Data is based on the consent of the Users for all cases where he/she transmits his/her Personal Data in order to benefit from the Services offered by MAINBOT. This consent can be withdrawn at any time.
The collection and the Processing are also based on the legitimate interest of MAINBOT, the execution of pre-contractual measures or of a contract with the Users, the respect of legal and regulatory obligations.
5. Recipients of Personal Data
With the exception of service providers that MAINBOT uses to provide the Services, MAINBOT is the sole recipient of the Personal Data collected and will not sell this Personal Data without your express consent.
The Personal Data will be processed exclusively on the territory of (i) France, (ii) and/or any other member state of the European Union, (iii) and/or any other signatory state of the agreement on the European Economic Area or Switzerland (iv) and/or any other state ensuring an adequate level of protection (hereafter referred to as the “Territory”.)
Apart from the cases mentioned above, any transfer of Personal Data to a third country requires the prior agreement of the Users and is subject to the respect of the laws on the protection of personal data in force.
MAINBOT may also share the Personal Data collected:
• with the companies it controls or those controlling it in the sense of articles L233-1 and following of the French Commercial Code,
• in the event of a sale, demerger, partial contribution of assets, or any other form of restructuring that it may undergo,
• in order to meet its legal and regulatory obligations.
6. Data security
MAINBOT protects and secures the Personal Data in order to ensure its security and prevent it from being distorted, damaged, destroyed or disclosed to unauthorized third parties. All persons having access to the Personal Data are bound by an obligation of confidentiality.
The Site uses technical cookies (hereinafter the “Cookies”).
A cookie is a small file for storing and retrieving information, generally made up of alphanumeric characters (cf. letters and numbers), deposited by a web server on the computer or electronic terminal of the user of the site to send state information to said browser and likewise obtain such information back from the browser. The status information can be for example a session identifier, a language, an expiration date, a response domain, etc.
Cookies usually make it possible to obtain certain information on the browsing habits of the user, his computer or his terminal, in particular in order to improve the content and the service offered by the site in question, to know the traffic of said site and to provide Internet
users with personalized services.
The notion of Cookies as used in this cookie management policy covers all types of tracers or other similar technologies, for example:
• HTTP Cookies;
• but also the use of other techniques:
o “local shared objects” sometimes called “Flash Cookies”;
o “local storage” implemented within HTML 5;
o identifications by calculating the fingerprint of the terminal (“device fingerprinting”);
o identifiers generated by operating systems (whether advertising or not: IDFA, IDFV, Android ID, etc.);
o hardware identifiers (MAC address, serial number or any other identifier of a device), etc.
o Google Ads, Facebook, Coinzilla, Linkedin, Reddit, TikTok, Twitter etc
In any case, Cookies can be:
• session Cookies, which disappear as soon as the user leaves the browser or the Site;
• where permanent Cookies that remain until the expiration of their lifespan or validity, or until the user deletes them by means of the functionalities of his browser for example or through the cookie management module set available on our Site.
These files are used to process statistics and information on traffic, to facilitate navigation and to improve the Site for the convenience of the Users.
This consent is considered valid for a maximum period of 13 (thirteen) months. At the end of this period, the Site will again request the User’s consent to save “cookies” files on his hard disk.
The User is informed that he/she may oppose the recording of these “cookies” files by configuring his/her browser software.
In the event that the User decides to deactivate the “cookies” files, he/she will be able to continue browsing the Site. However, any malfunctioning of the Site caused by this manipulation could not be considered as being due to the editor of the Site.
b) Description of the cookies used by the Site
The editor of the Site draws the attention of the Users to the fact that the following cookies are used during his navigation:
• Google Analytics – traffic and visit analysis;
• Polylang – Multilanguage.
8. Data retention
MAINBOT keeps the Personal Data for the time necessary to achieve the purposes pursued, subject to the legal possibilities of archiving, obligations to keep certain Personal Data, and/or anonymization.
Considering the Blockchain technology used, the Users are aware that this technology does not allow the deletion of information anchored on it. However, MAINBOT takes all appropriate technical measures to pseudonymise and/or make inaccessible Personal Data that must
survive their deletion.
Concerning the Personal Data processed outside the Blockchain, the retention periods are as follows:
• For accounting purposes: 10 years from the end of the accounting period;
• For the purposes of preventing money laundering and the financing of terrorism, and the fight against corruption: 5 years after the end of the relationship with MAINBOT;
• For the needs of identification and management of the Users and Content Creators: for the duration of the contractual relations increased by 2 years;
• For the needs of recruitment within MAINBOT: for the duration necessary to process the application and 3 years after the last Users.
You benefit, under the terms and conditions and within the limits defined by the legal and regulatory provisions on the protection of Personal Data and non-personal data, the following rights with regard to your Data:
• Right of access: you can obtain confirmation whether or not Personal Data concerning you is processed by the Company and, when they are, access to said Personal Data, as well as certain information relating to the Processing of your Personal Data and the characteristics of such Processing;
• Right of rectification: you can request the correction of your Personal Data that you consider incomplete or inaccurate;
• Right to erasure: you can, in certain cases, request the erasure of your Personal Data (except for example if they are necessary for the execution of your contractual relations with the Company where applicable, or if they are necessary for the Company to comply with its legal or regulatory obligations or to ascertain or exercise its rights);
• Right to limitation of Processing: you can request limitation of Processing of your Personal Data, allowing you to request in certain cases the marking of your Personal Data in order to limit future Processing;
• Right to the portability of your Personal Data: you have the right in certain cases and under certain conditions to request to receive the Personal Data concerning you that you have provided to us or, when technically possible, to they are transferred to a third party, in a machine-readable form (it being specified that this right to data portability only applies to Processing based on the consent of the Persons concerned or on the execution of contractual relations, and this provided that the Data Processing is carried out using automated processes);
• Right to withdraw your consent: you can withdraw your consent if the Processing is carried out on the basis of your consent, without the withdrawal of such consent prejudicing the lawfulness of the Processing based on the consent made before the withdrawal of it;
• Right to object to the processing of Personal and non personal data; • Right to define guidelines for the retention, erasure or communication of your Personal Data after your death: in this regard, in the event of death which would be brought to our attention, please be aware that your Personal Data will in principle be deleted (unless it is necessary to keep it for a specified period for reasons relating to our legal and regulatory obligations), after having been communicated to a third party possibly designated by you.
Regarding the Processing of your Personal Data and non-personal data implemented by the Company, these rights are exercised:
(i) by email to the following email address: email@example.com and firstname.lastname@example.org or,
(ii) by post to the address next: 33 Avenue du Maine,Tour Maine, Montparnasse, 45ème étage, 75755 Paris Cedex 15
In any event, in the event of reasonable doubt as to the identity of the person submitting such a request to exercise their rights, the Company may always request that it be provided with additional information necessary to confirm the identity of the Person concerned and request for this purpose, when the situation so requires, a photocopy of an identity document bearing the signature of the holder. In such a case, the aforementioned response times will be suspended pending receipt of the additional information necessary to identify the Data Subject.
If such a request is received, it will be answered as soon as possible and in any event within a maximum period of one month from receipt of the request. If necessary, this period may be extended by two months, taking into account the complexity and the number of requests
received, in which case the applicant will be informed.
The request may be presented by the Data Subject or by a person specially authorized for this purpose by the Data Subject, provided that this authorized person can prove his identity and the identity of the principal, his mandate as well as the duration and of the precise object
thereof. The mandate must also specify whether the representative can be made the recipient of the response.
You also have in any event the right to lodge a complaint with the competent supervisory authority (in France, this is the National Commission for Computing and Liberties known as "CNIL": 3 place de Fontenoy, TSA 80715 - 75334 Paris Cedex 07; tel.: 01 53 73 22 22) if you believe that the Processing of your Personal Data is not carried out in accordance with the legal and regulatory provisions on Data Protection of a personal nature.
To understand your rights, you can also refer to the explanations provided by the Cnil here: https://www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles.
We point out that in application of articles L.223-1 et seq. Of the Consumer Code, you can, if you are a consumer, object at any time to being canvassed by telephone, by registering for free on the site "www.bloctel.gouv.fr".