Privacy Policy

Dirty Burger Club Ltd

PRIVACY AND COOKIE NOTICE
(Last updated September 2022)

1.  Who are we?

We are Dirty Burger Club Ltd, a company incorporated and registered in the British Virgin Islands with registered address at 4th Floor, Banco Popular Building, Road Town, Tortola VG1110, British Virgin Islands, and registered number 2109305 (“DBC”). “We” and/or “us” refers to DBC.

Where we decide the means or purpose of processing your personal data, we are the “data controller”.

2.  What’s this notice about?

DBC is committed to protecting your personal data. This notice explains how we process personal data, as a data controller, relating to:
the unique, randomly generated artwork known as “DBC” (“DBC NFTs”);
the request for the creation of new DBC NFTs, submitted by individuals via their cryptographic wallet, and delivered on the cryptographic wallet from which the request was submitted (“Minting”); and
our website: www.dirtyburgerclub.io (“Website”).

This notice applies to both current and prospective holders of DBC NFTs (“NFT Holders”, “you” and “your”). We update this notice from time to time, so please check back in on a regular basis.

Please note that other websites or services mentioned on the Website are not operated by us, and you should refer to the privacy policies on those websites to understand how your personal data is being used. The Website and the Minting are not intended for children and we do not knowingly collect data relating to children.

3.  What are your rights?

You have the following rights, although these rights may be limited in some circumstances:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

4.  How do you contact us?

If you have any questions concerning this notice, including how you can exercise your rights, please contact us at info@dirtyburgerclub.io. If we can’t resolve your issue, you can also get in touch with the Office of Information Commissioner.


5.  Your data and how we use it

Please see the table below.

Your data

How we use it

Sources and recipients

Minting Data

We process the following information in connection with the Minting:

  • Cryptographic wallet address

  • List ItemAny POAP (proof of attendance protocol) NFTs made available by DBC (directly or indirectly) (“POAPs” )

  •  Mint price paid for DBC NFTs

  • Information relating to illicit activities or high-risk activities concerning the NFT Holder or any POAPs held by an NFT holder

  • IP address

  • Email

  • Social media usernames

  • Any other information that you submit as part of any competition entries or submissions

We process this information because it is necessary:

  • For the performance of a contract to which the NFT Holder is a party or in order to take steps at the request of the NFT Holder prior to entering into a contract to which the NFT Holder is party or in order to take steps at the request of the NFT Holder prior to entering into a contract

  • To comply with a legal obligation to which DBC is subject

  • For the purposes of our legitimate interests, being to: (i) ensure that the Website and the Minting functions properly; (ii) improve the quality of the Website; and (iii) promote the success of the Minting, the Website and our business as a whole (the “DBC Legitimate Interests”)

We collect this data:

  • Directly from you

  • Via a self-executing protocol referred to as a Smart Contract

  • Wert.io who runs checks on your cryptographic wallet address to verify whether it is associated with any illicit activities, or with any high-risk activity from an anti-money laundering and terrorist financing perspective. You can access their website here: https://wert.io/for-nft

Analytics Data

We process the following information to track customer demographics, and also to improve our site:

  • Twitter username

  • Likes/retweets

  • Active followers

  • Mutual followers

  • Mentions

  • Internet protocol (IP) address

  • Browser type and version

  • the pages you viewed,
    page response times,
    download errors, length of
    visits to certain pages and
    page interaction
    information

We process this information because it is necessary for the DBC Legitimate Interests

We collect this data:

  • Directly from you

  • From Google Analytics, you can find their privacy policy here:
    https://dirtyburgerclub.io/terms-and-conditions/

Enquiry Data

We process the following information so that we are able to collect, record and properly respond to your submissions, enquiries and support requests in relation to the Website, the Minting and DBC NFTs:

  • Name

  • Cryptographic wallet
    address

  • Contact information (such as email address)

  • Social media usernames

  • Any other information that
    you provide to us as part
    of any submission, enquiry
    or support request

We process this information because it is necessary for the DBC Legitimate Interests

We collect this data:

  • Directly from you

6.  Cookies, analytics and similar technologies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly. 

Our website uses cookies. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse the Website and also allows us to improve the Website. Please see the table below for more information

Cookie/data

Duration

Purpose

Access

Google Analytics

Duration of visit to the Website

To track your behaviour on our Website and improve the Website’s performance.

We use Google Analytics. and you can access their privacy policy:
https://support.google.com/analytics/answer/7318509?hl=en



Local storage of NFT Holder leaderboard

24 hours

To improve performance so we don't need to reload data that changes only periodically

Only the Website itself accesses and

uses the data stored to the NFT Holder’s browser’s local storage. It is not shared with anyone outside of DBC.

Cookie for policy acceptance

Until removed

To prevent NFT Holders from having to consent to cookies before every visit to the Website

Only the Website itself accesses and
uses the data stored to the NFT Holder’s browser’s local storage. It is not shared with anyone outside of DBC:
https://cookieinfoscript.com/legal.html

7.  Storage, transfers and disclosure

Data retention

We hold the Enquiry Data for one year following the date on which the relevant enquiry

has been closed. In respect of other personal data described in this notice, we hold it for as long as it is necessary to continue to retain that personal data to achieve the relevant purposes (taking into account the amount, nature, and sensitivity of the personal data, the potential risk of unauthorised access, and legal requirements).

Storage & transfers

The personal data described in this notice is generally stored in United Kingdom. Where we transfer personal data internationally, we will implement appropriate measures (where required by data protection laws) in order to safeguard such transfers. For more information drop us a line using the contact details at the start of this notice.

Disclosure

We may disclose your personal data:

  • Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies).
  • With suppliers and subcontractors, as necessary for the purposes set out in this notice.
  • With other members of our corporate group and our international network of partners.
  • If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.