Effective date 5th of September 2022
For more information on our contact details see par. 11 “How to Contact Us”. We are committed to safeguarding your privacy. Therefore, we encourage you to read this policy carefully.
1. Who Are We
2. What does this Policy cover?
3. Types of Information Collected
4. How we collect the personal information
5. Use of Information Collected
6. Legal Basis
7. Information Sharing2
8. Security and Retention
9. Your Rights
10. Children’s Privacy
11. How to Contact Us**
12. Users Outside of the European Economic Area (“EEA”).
13. Changes to Police
Who Are We
Nebula LLC (Company registered under the laws of Georgia, legal address: Georgia, Tbilisi, Vake district, Ilia Chavchavadze Avenue, N 11, apartment 45) (“Nebula”, “us”, “we” or “our”) operates the online website and platform Ownic.
Ownic aims to revolutionize the culture of sports collectibles and enables users to acquire, collect, showcase, exchange, and play Non-Fungible Tokens (the “DIGITAL CARD”) featuring professional football players (the “Services”).
We have determined our respective responsibilities for compliance with our obligations under applicable privacy legislation for processing your personal information concerning our global processing activities through an arrangement between you and us. In summary, we have arranged that if you want to exercise your rights, such as your right to access, correct, erase, restrict, object or port personal information or to withdraw your consent, or if you have any questions about the processing of your personal information, you can contact us in accordance with par. 11 “How to Contact Us”.
Nebula ensures that you can exercise your rights and that your questions will be handled within a reasonable time frame.
What does this Policy cover?
This Policy applies to personal information collected by the Nebula through your use of the Ownic and Services.
Your privacy is important to us. We therefore take the protection of your personal information and its confidentiality very seriously. Your personal information is processed only within the scope of the statutory provisions of data protection law, in particular the EU General Data Protection Regulation (GDPR).
You should read this Policy together with any other privacy information which may be provided on specific occasions when personal information about you is collected on the Ownic. That will ensure you are fully aware of how and why we are using your data. This Policy supplements any other notices and is not intended to override them.
Types of Information Collected
We may collect, use, store and transfer different kinds of personal information about you. For the purpose of this Policy we have grouped these together as follows:
Identity Data such as your name(s), username or similar identifier, marital status, title, date of birth, gender and job title (where relevant).
Contact Data such as your address, billing address (where different), email address, preferred language and telephone numbers.
Financial Data such as your bank account, PayPal account and/or payment card details.
Electronic Wallet Address such as your Meta Mask wallet information address.
Technical Data such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types versions and statuses, operating system and platform and other technology on the devices you use to access the Ownic.
Communications Data includes information you provide when communicating with us, your preferences in receiving marketing from us and our third parties and (where relevant) any other communication preferences.
Profile Data such as your username and password, associated social media accounts, your interests, preferences, posts or comments on interactive features (if any), feedback and/or survey responses.
How we collect the personal information
We use different methods to collect data about you, including through:
- Direct interactions. You may give us your Identity, Contact, Financial, Communication and certain Profile Data by filling in forms or by corresponding with us using contact details we provide on Ownic.
- Third parties or publicly available sources. We may receive personal information about you from various third parties.
We may also supplement the information collected with other information that we obtain from our dealings with you or which we receive from other organisations, such as our commercial partners, and group companies.
Use of Information Collected
The main purposes for which we use your personal information are:
- To operate Ownic and provide you Services. While using Ownic, we may require from time to time your personal information, in order to provide Services.
- To communicate with you. If you send us an e-mail or communicate with us online or via social media, we process your data to respond to you.
- For statistical research. We use automatic tools (such as cookies) to perform statistical research into general trends regarding the use of this website and the behavior of the website’s visitors to improve this website.
- For record-keeping and to comply with statutory obligations. We collect, store and use your data for internal business purposes, such as record keeping, and to comply with our legal and fiscal obligations.
- To process your order. If you place an order on this website, we work on your data to process your order.
- To improve the quality of our application. If you register on our application, we work on your data to improve our service.
We collect, use, and store your personal information to comply with the legal obligations we are subject to, if necessary for our legitimate interests or the interests of a third party, for the execution of an agreement, or on the basis of your consent.
If we data process your personal on the basis of your consent, you may withdraw your consent at any time by following the specific instructions in relation to the processing for which you provided your consent, by adjusting your settings (if available), or by contacting us (please see par. 9 ‘Your Rights’ below).
When we process your personal information for our legitimate interests or the interests of a third party, we have balanced these interests against your legitimate interests. Where necessary we have taken appropriate measures to limit implications and prevent unwarranted harm to you. Our legitimate interests may, for example, include security and safety purposes, to improve this website, or to provide better products and offers to you. More information on the balancing tests we perform is available upon request. Where we process your personal information for our legitimate interests or the third-party interests, you have the right to object at any time on grounds relating to your particular situation (please see par. 9 ‘Your Rights’ below).
Where we process your personal information for a purpose other than that for which we collected it initially (and we rely on a legal basis other than consent or complying with legal obligations for this new purpose), we will ascertain whether processing for this new purpose is compatible with the purpose for which the personal information were initially collected. More information on this assessment is available upon request (please see par. 9 ‘Your Rights’ below).
Generally, we do not sell or share your personal information with anyone outside Nebula. However, we do disclose or share data with the following categories of recipients for the following purposes:
- For the support services we involve. We use third parties for support services to this website, such as IT suppliers (for example, SalesForce CRM system for processing your orders), social network providers, marketing agencies, credit and charge card companies, and anti-fraud screening service providers. All such third parties will be required to adequately safeguard your personal information and only process it by following our instructions.
- Statistical research. For statistical research, we make use of third-party software such as Google Analytics or social media platforms. These platforms also have access to the data they collect. For example, when you accept cookies for this website, we analyze cookie data for statistical research via Google Analytics.
- Ownership of Nebula changes. If the ownership of Nebula changes as a result of a merger, acquisition, transfer, sale of assets, reorganization, or bankruptcy your personal information may be transferred to the successor entity.
- Public authorities. If we are required to by law, we also collect and share your identifying information with public authorities or governmental organizations.
- Third-party websites. This website contains links to third-party websites; if you follow these links, you exit our website. While these third-party websites are selected with care, we cannot accept liability for the use of your personal information by these organizations. For more information, please consult the privacy statement of the website you are visiting (if such a statement is provided).
Security and Retention
Nebula ensures that your personal information are properly secured by appropriate technical and organizational measures so that they are protected against unauthorized or unlawful use, alteration, unauthorized access or disclosure, accidental or wrongful destruction, and loss.
You may contact us (please see par. 11 ‘How to Contact Us’ below) to exercise any of the rights you are granted under applicable data protection laws:
- Right to access. You may ask us whether or not we process any of your personal information and, if so, receive access to that data in the form of a copy. When complying with an access request, we will also provide you with additional information, such as the purposes of the processing, the categories of personal information concerned as well as any other information necessary for you to exercise the essence of this right.
- Right to rectification. You have the right to have your data rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate personal information about you and, taking into account the purposes of the processing, complete incomplete personal information, which may include the provision of a supplementary statement.
- Right to erasure. You also have the right to have your personal information erased, which means the deletion of your data by us and, where possible, by any other controller to whom your data has previously been made public by us. Erasure of your personal information only finds a place in certain cases, prescribed by law and listed under article 17 of the GDPR. Certain cases include situations where your personal information are no longer necessary in relation to the initial purposes for which they were processed as well as situations where they were processed unlawfully. Due to the way we maintain certain services, it may take some time before backup copies are erased.
- Right to restriction of processing. You have the right to obtain the restriction of the processing of your personal information, which means that we suspend the processing of your data for a certain period of time. Circumstances that may give rise to this right include situations where the accuracy of your personal information was contested but some time is needed for us to verify their (in)accuracy. This right does not prevent us from continue storing your personal information. We will inform you before the restriction is lifted.
- Right to data portability. Your right to data portability entails that you may request us to provide you with your personal information in a structured, commonly used, and machine-readable format and to have such data transmitted directly to another controller, where technically feasible. Upon request and where this is technically feasible, we will transmit your personal information directly to the other controller.
- Right to object. You also have the right to object to the processing of your personal information, which means you may request us to no longer process your personal information. This only applies in case the legitimate interests ground constitutes the legal basis for processing.
At any time and free of charge you can object to direct marketing purposes in case your personal information are processed for such purposes, which includes profiling purposes to the extent that it is related to such direct marketing. In case you exercise this right, we will no longer process your personal information for such purposes.
You may withdraw your consent at any time by following the specific instructions in relation to the processing for which you provided your consent, by adjusting your settings (if available), or by contacting us (please see par. 11 ‘How to Contact Us’).
Under conditions, we are entitled to deny or restrict your rights as described above. In any case, we will carefully assess whether such an exemption applies and inform you accordingly.
We may, for example, deny your request for access when necessary to protect the rights and freedoms of other individuals or refuse to delete your personal information in case the processing of such data is necessary for compliance with legal obligations. The right to data portability, for example, does not apply in case the personal information was not provided by you or if we process the data not on the basis of your consent or for the performance of a contract.
When you would like to exercise your rights, all you have to do is send your request to us using the contact details stated below (please see par. 11 “How to Contact Us”).
We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of the Ownic and/or Services is directed to children. If you learn that a child has provided us with personal information in violation of this Policy, then you may alert us using the contact details stated below (please see par. 11 “How to Contact Us”).
How to Contact Us
If you have any questions or concerns regarding the Policy related to our website, please feel free to contact us at:
Mailing Address: N37 Chavchavadze Ave., Tbilisi, Georgia, ZIP code: 0162
Users Outside of the European Economic Area (“EEA”)
If you are a non-EEA user of the Service, by visiting the Ownic and providing us with data, you acknowledge and agree that your Personal Information may be processed for the purposes identified in the Policy. In addition, your Personal Information may be processed in the country in which it was collected and in other countries, including EEA, where laws regarding processing of Personal Information may be less stringent than the laws in your country. By providing your Personal Information, you consent to such transfer.
Changes to Police
This Policy was most recently amended on the effective date indicated in the upper left corner above and replaces earlier versions. We may update and/or change the terms of our Policy, and we will post any substantive changes on our website and provide them to you by e-mail prior to these changes taking effect, so that our users and/or visitors are aware of the type of information we collect, how it will be used, and under what circumstances if any, we may disclose such information.