1.2 - We will never Process particularly sensitive Personal Data, such as information in relation to a natural person’s health, sexual orientation, racial or ethnic origin, political opinions, religious beliefs, trade union membership or genetic and biometric data used for the purpose of uniquely identifying an individual. As a reminder, Anima’s services are only available to adults. We do not store biometric data.

1.3 - When we say that we Process Quest User's Personal Data to pursue a legitimate interest, this takes into account data subjects’ rights to data protection, which cannot be overridden. Without limitation, we may for example Process data to enhance the quality of our services, protect our interests and enforce agreements. To obtain further information about how we assess our legitimate interests against any potential impact on data subjects in respect of specific activities please contact us.

1.4 When we request information from Quest User in order to meet any of our legal requirements or to perform our contractual obligations, failure to provide us with such information will mean that Quest User will not have access to part or all of our services.

1.5 We do not use consent as a legal basis for Processing Quest User's Personal Data other than in relation to our use of cookies (please consult our Cookies Policy), to verify Quest User is a human and to conduct surveys or get feedback or send marketing communications via email.

2 - Security and Confidentiality

2.1 - We are committed to protecting Quest User's privacy. We take all reasonable endeavours to protect and safeguard the confidentiality, integrity, availability, and resilience of Quest User's Personal Data.

2.2 - We have implemented measures to prevent Quest User's Personal Data from being accessed by unauthorised third parties, falsified or damaged.

2.3 - Furthermore, within Anima, our personnel Process Personal Data on a need-to-know basis or whenever it is reasonably necessary, in order to perform their duties and subject to a duty of confidentiality.

2.4 - We have put in place procedures to deal with any actual or suspected data breach and will notify Quest User and any applicable regulator of a breach where we are legally required to do so. While we take all reasonable endeavours to protect and safeguard Personal Data, the transmission of information via the Internet is not completely secure. We do our utmost to protect Quest User's Personal Data but we cannot guarantee the security of Quest User's data transmitted to us over email or through the DApp; any transmission is at Quest User's own risk.

2.5 - For Quest User's safety, please make sure to keep us informed whenever Quest User's Personal Data needs to be updated by lodging a request at [email protected]. We will endeavour to effect all necessary modifications within a reasonable timeframe.

3 - Data Transfers

3.1 - Quest User's Personal Data is stored on our servers, located within the European Union.

3.2 - As necessary, we will share Quest User's Personal Data (i) with selected third-party service providers such as our analytics and search engine providers that assist us in the improvement and optimization of the DApp and/or the services; our proof-of-personhood providers and other relevant providers to the extent necessary to supply the services to Quest User, such as without limitation our banks, attorneys, consultants, contractors or Cloud service providers; (ii) with public authorities and law enforcement agencies worldwide either when ordered to do so or on a voluntary basis if this appears reasonable and necessary to us; and (iii) with relevant third parties when we are under a duty to disclose or share Quest User's Personal Data in order to comply with any legal obligation, or in order to enforce or apply our Anima Quest Terms and/or other agreements; or to protect the rights, property, or safety of our clients, others or ourselves, including to defend ourselves from legal claims.

3.3 - The list of the third-party service providers with whom we may share Personal Data is available upon legitimate request by contacting [email protected].

3.4 - Personal Data and other data may, occasionally, be exported and Processed outside of the jurisdiction in which Quest User resides. Under those circumstances, the governments, courts, law enforcement, or regulatory agencies of that country or those countries may be able to obtain access to Quest User’s Personal Data through foreign laws. Quest User needs to be aware that the privacy standards of those countries may be lower than those of the jurisdiction in which Quest User resides.

4 - Data Retention Periods

4.1 - We retain Personal Data for as long as necessary to provide our services or for other legitimate purposes, such as complying with our legal obligations, resolving disputes and enforcing our agreements. When we do so in order to perform our contractual obligations, the data is retained for a period not exceeding 5 years as of the deletion of a Quest User’s account. When consent is the sole legal basis justifying the Processing of Personal Data, deletion takes place immediately after we acknowledge receipt of Quest User’s written notice communicating his or her withdrawal of consent. Note that Processing operations which took place before Quest User revoked his or her consent will not become illegal on withdrawal. Please note that on-chain data is public data and may therefore not be deleted, such as blockchain transactions in relation to your personal NFTs.

4.2 - Because these needs can vary for different data types, the context of our interactions with Quest User or his or her use of our services, actual retention periods may vary significantly. Criteria used to determine the retention periods include: (i) whether direct access is given to Quest User to delete the Personal Data at any time (e.g., in the dashboard)—if not, a shortened data retention time will generally be applied; (ii) whether Quest User has provided consent for a longer retention period—if so, we will retain Personal Data in accordance with Quest User's consent; and (iii) whether we are subject to legal, contractual or similar obligation to retain or delete the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, data retained for the purposes of litigation or for accounting or tax purposes.)

4.3 - Data retained in our archives is encrypted. Archived data remains accessible only to limited Anima staff members, following an ad hoc procedure. Data accessible on our servers is also encrypted. We may retain anonymised aggregated data for a longer period of time.

5 - Quest Users Rights

5.1 - Quest Users have a number of rights in relation to how we Process their Personal Data, which may be exercised by contacting us at [email protected].

5.2 - These include the right to: (i) know what Personal Data we collect, use, disclose, share and sell; (ii) delete Quest User's Personal Data in certain circumstances, for example, where it is no longer necessary for us to Process Quest User's Personal Data to fulfil our Processing purposes; (iii) complete or rectify Quest User's incomplete or incorrect Personal Data; (iv) restrict the Processing of Quest User's Personal Data where, for example, the information is inaccurate or it is no longer necessary for us to Process such information or where Quest User have exercised his or her right to object to our Processing; (v) object to the Processing of Quest User's Personal Data which may be exercised in certain circumstances, or where Quest User's own legitimate interests outweigh ours; (vi) receive a copy of Quest User's Personal Data; (vii) have Quest User's Personal Data ported to a new service provider if Quest User no longer wish to use the services; and (viii) when we rely on Quest User's consent to Process his or her Personal Data (cookies and newsletter/marketing communication), Quest User have the right to withdraw his or her consent at any time. For cookies, this is done by setting up the cookie’s preferences. Please visit our Cookies Policy. For newsletters, Quest User can do so by opting-out using the link provided in the newsletters at any time. We will do our best to honour Quest User's request promptly.

5.3 - Quest User will not have to pay a fee to access Quest User's Personal Data or to exercise any of Quest User's other rights. We may charge a reasonable fee if Quest User's request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with Quest User's request in these circumstances.

5.4 - We may need to request specific information from Quest User to help us confirm Quest User's identity and ensure Quest User's right to access Quest User's Personal Data (or to exercise any of User's other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

5.5 - We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if Quest User's request is particularly complex or Quest User have made a number of requests. In this case, we will notify Quest User and keep Quest User updated.

5.6 - For any request concerning personal data, please send an email to the following address: [email protected].

5.7 - Quest Users may raise a concern or lodge a complaint with the French Data Protection Authority (the “CNIL”) if dissatisfied with how we handle their privacy request.

6. Changes to this Privacy Notice

Any changes we make to our Privacy Notice in the future will be posted on this page.