1. Introduction
This Privacy Notice ("Notice") explains in detail how Family Labs Ltd ("we", "us", "our", or "Company") collects, uses, shares, and protects personal information in connection with the Family Sweepstakes ("Sweepstakes"). We are committed to protecting your privacy and handling your data in an open and transparent manner. By participating in the Sweepstakes, you acknowledge that you have read and understood this Notice and agree to the practices described herein.
2. Data Controller
Family Labs Ltd is the data controller for the personal information collected in connection with the Sweepstakes.
3. Information We Collect
- X profile username
- Family wallet address
- Email address (for winners only)
- Know Your Customer (KYC) information (for winners only), which may include:
- Full legal name
- Date of birth
- Residential address
- Government-issued identification information
- Any other information necessary to comply with legal and regulatory requirements
4. Legal Basis for Processing
We process your personal information based on the following legal grounds:
- Contractual necessity: To perform our obligations under the Sweepstakes rules
- Legal obligation: To comply with applicable laws and regulations
- Legitimate interests: To administer the Sweepstakes and prevent fraud
- Consent: Where required by law, we will obtain your explicit consent for certain processing activities
5. How We Use Your Information
We use the collected information for the following purposes:
- To administer and manage the Sweepstakes
- To verify the eligibility of participants and winners
- To communicate with participants and winners
- To distribute prizes
- To comply with legal and regulatory requirements, including anti-money laundering and know-your-customer obligations
- To prevent and detect fraudulent or suspicious activities
- To analyze and improve our services and user experience
- To respond to your inquiries and provide customer support
- To enforce our terms and conditions and protect our legal rights
6. Information Sharing and Disclosure
We may share your information with the following categories of recipients:
6.1 Service Providers
We may share your information with third-party service providers who perform services on our behalf, such as:
- Sweepstakes administration and management
- Identity verification and KYC providers
- Customer support services
- Analytics providers
- Cloud storage providers
These service providers are obligated to protect your information and may not use it for any purpose other than providing services to us.
We may disclose your information to legal and regulatory authorities, law enforcement agencies, or other third parties:
- When required by applicable law, regulation, legal process, or governmental request
- To enforce our terms and conditions or protect our legal rights
- To detect, prevent, or investigate potential security incidents or fraud
- To protect the vital interests of any person
6.3 Corporate Affiliates
We may share your information with our corporate affiliates (companies under common ownership or control) for the purposes outlined in this Notice.
6.4 Business Transfers
In the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, your information may be transferred to our successor or assignee. We do not sell, rent, or lease your personal information to third parties.
7. International Data Transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country.
We have implemented appropriate safeguards to protect your personal information when it is transferred internationally, including entering into Standard Contractual Clauses with recipients of your data, and other organizational measures to ensure adequate protection.
8. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized or unlawful processing, accidental loss, destruction, or damage. These measures include:
- Encryption of sensitive data in transit and at rest
- Regular security assessments and penetration testing
- Access controls and authentication mechanisms
- Employee training on data protection and security
- Physical security measures for our facilities
However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
9. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes outlined in this Notice, unless a longer retention period is required or permitted by law.
When we no longer need to process your personal information, we will either delete or anonymize it, or if this is not possible, we will securely store your personal information and isolate it from any further processing until deletion is possible.
10. Your Rights
Depending on your jurisdiction, you may have certain rights regarding your personal data. These may include:
- Right to access: You can request a copy of the personal information we hold about you.
- Right to rectification: You can request that we correct inaccurate or incomplete information.
- Right to erasure: You can request that we delete your personal information in certain circumstances.
- Right to restrict processing: You can request that we limit the processing of your information in certain circumstances.
- Right to data portability: You can request a copy of your information in a structured, commonly used, machine-readable format.
- Right to object: You can object to our processing of your information in certain circumstances.
- Right to withdraw consent: Where processing is based on consent, you can withdraw your consent at any time.
To exercise these rights, please contact us using the information provided in Section 15. We may need to verify your identity before responding to your request. We will respond to your request within the timeframe required by applicable law.
11. Third-Party Services
The Sweepstakes involves the use of third-party services, including X and the Family wallet application. These services have their own privacy policies, and we encourage you to review them. We do not accept any responsibility or liability for the privacy practices of these third parties.
12. Children's Privacy
The Sweepstakes is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18 without verification of parental consent, we will take steps to remove that information from our servers.
13. Changes to This Privacy Notice
We may update this Privacy Notice from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the new Privacy Notice on our website. We encourage you to review this Notice periodically.
14. Consent
By participating in the Sweepstakes, you consent to the collection, use, sharing, and processing of your personal information as described in this Privacy Notice. You may withdraw your consent at any time by contacting us, but please note that this may affect your ability to participate in the Sweepstakes.
15. Governing Law
This Privacy Notice and any disputes relating to it are governed by the laws of Cayman Islands, without regard to its conflict of law principles.
16. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Notice or our data practices, please contact us at: [email protected]