We at Sulake Oy (“Sulake”, “Habbo”, “we”, “us” or “our”) respect your privacy and recognise the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data.
The purpose of this NFT privacy notice (“Privacy Notice”) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you,“Personal Data”) when you access our website and related services. This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.
This Privacy Notice applies whenever you use our services within our website https://nft.habbo.com/(“Service Website”), all of which together we refer to as “Services”.
1. Who is Responsible for the processing of your Personal Data?
Sulake Oy, Dagmarinkatu 6, 00100 Helsinki, Finland is responsible (“the Data Controller”) for the processing of your Personal Data when you visit our Service Website or use our Services.
2. What types of Personal Data do we process and how do we collect it?
- We process a limited set of your personal data in relation to the Habbo NFTs and/or Art for which we are considered the controller as defined in Article 4(7) of the General Data Protection Regulation (EU 2016/679).
- We may process the following categories of personal data for the purposes indicated below:
(a) Handling your purchase of the Habbo NFT and/or license of the Art
- Your MetaMask wallet ID
- Publicly available information: your transactions and assets in the Ethereum blockchain network (EtherScan), such as your purchased Habbo NFT and/or Art, and transactional information, such as the purchase price of your Habbo NFT and/or Art
- IP address
(b) Use of the Habbo NFT in Habbo
- Your MetaMask wallet ID
- Publicly available information: your transactions and assets in the Ethereum blockchain network (EtherScan), to determine whether you (still) own a Habbo NFT (publicly available information)
- Your Habbo account information, further explained in the Habbo Privacy Notice
- Perks in Habbo related to the ownership of a Habbo NFT
(c) Aftersales of the Habbo NFT
- Your MetaMask wallet ID
- Publicly available information: your transactions and assets in the Ethereum blockchain network (EtherScan), such as the resale of your Habbo NFT or Art, the selling price of your Habbo NFT and Art, and the MetaMask wallet ID of the new Habbo NFT and/or Art owner
(d) Communication (through Discord)
- Discord ID, content of the message
(e) To comply with our legal obligations, for instance in relation to fraud prevention, detection, money laundering and terrorist financing legislation
- All personal data mandatory prescribed by the applicable law, such as the transactional data associated with purchasing and resale of the Habbo NFT
- Your personal data processed for the purposes (a), (b) and (c) is necessary for the performance of the Habbo NFT General License Terms and Conditions. The processing of your personal data for purpose (e) is necessary for complying with a legal obligation to which we are subject.
- In relation to the purposes (a), (c) and (d), you may (be required to) disclose personal data to third parties, such as ConsenSys AG (MetaMask), Ozone Netweroks, Inc. (OpenSea), Ethereum and Discord, Inc.. Please consult their respective privacy statements for more information on how your personal data is processed by these third parties.
- Ethereum requires the payment of a transaction fee (called a “Gas Fee”) for every transaction that occurs on the Ethereum network. You will be solely responsible to pay the Gas Fee. You agree to hold the Company harmless for any losses you may incur as a consequence of minting or buying your Habbo NFT. These potential losses include any Gas Fees for failed transactions, any excessive Gas Fees charged due to website or smart contract bugs, and any loss of your Habbo NFT due to website or smart contract bugs.
- Additional information about how we process and protect your personal data in relation to the Habbo NFTs and/or Art, as well as your rights under the GDPR and how you can contact us can be found in the Habbo Privacy Notice.
3. On which legal basis do we process your Personal Data?
- Performance of a contract: We process your Personal Data for the performance of a contract or to take steps prior to entering into a contract to which you are party, for example, where it is necessary for the sale and after sale of an NFT, in game integration of an NFT, and to enable users join the Discord channel.
- Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations, for example, for tax and accounting purposes or legal disputes.
- Legitimate interests: We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we process your Personal Data for improvement of the Service provided to you or to provide you with a better user experience or we transfer your personal data across all our group companies for administrative transfers as well as to determine the size of the user base of our Services. and we process your personal data to obtain statistics concerning popularity of our Services within the context of group company products and services.
4. With whom do we share your Personal Data?
We will not disclose your Personal Data to any party who is not authorised to process them. To manage our Services, we will share your Personal Data internally with members of our responsible departments, technical support or customer support and in each case only if access to your Personal Data is necessary for the performance of their roles. Moreover, and only when necessary to fulfil the purposes mentioned above, we disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services:
- Group companies: We share your personal data with our group companies which are responsible for internal analytics for the purposes of cross-product audience measurement. Where we share your personal data with our group company, we have appropriate agreements (an intra-company data sharing agreement) in place to ensure that your personal data is processed in compliance.
- External service providers: We share your Personal Data with external service providers who perform services on our behalf, like customer support services, IT services, hosting and content delivery services. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.
- Law enforcement, government authorities or courts: We disclose your Personal Data in response to lawful requests from public authorities, including law enforcement, government authorities, supervisory authorities or courts.
- Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).
5. Where will my Personal Data be processed?
In general, your Personal Data is stored on servers outside the European Union (EU)/the European Economic Area (EEA). We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission’s standard data protection clauses (also known as Model Clauses) to provide safeguards for your Personal Data.
6. How do we protect your Personal Data?
We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.
7. How long do we store your Personal Data?
We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was collected or to fulfil our legal obligations or necessary for the establishment, exercise or defence of legal claims or resolving disputes. Afterwards, we will delete or anonymize your Personal Data. Please seebelow for service specific information about how long we will retain your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available here.
8. What are your rights in respect of your Personal Data?
To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:
- the right to access the personal data we hold about you
- the right to request the update or correction of your personal data
- the right to receive your personal data in a structured, commonly used and machine-readable format
- the right to request the deletion of your personal data
- the right to restrict the processing of your personal data
- the right to withdraw your consent
- the right to object