Privacy Policy

Last updated: 01/06/2024

This privacy policy is subject to change.

We acknowledge our responsibilities regarding the collection, retention, processing, utilization, and/or transfer of personal data. Safeguarding your privacy is of paramount importance to us.

This policy (referred to as “this Policy”) delineates our procedures for the collection, utilization, storage, and disclosure of your personal data. We kindly request that you take a moment to peruse this Policy to gain insight into how we gather, employ, and/or divulge your personal data. Familiarizing yourself with these practices will help you understand the purposes for which we collect, use, and/or disclose your personal data. By accessing the website at https://larkena.com.

and its sub-domains (collectively referred to as “the Website”), our desktop launcher application, the Order of Danann game, and our metaverse MythDeck, you hereby express your agreement and consent to Larkena (the Company), its affiliated entities, business divisions, and associates, along with their respective representatives and/or agents (collectively mentioned as “we,” “us,” or “our”), gathering, utilizing, revealing, and sharing your personal data amongst themselves. You also consent to the disclosure of such personal data to relevant third-party providers.

Please note that this Policy is intended to supplement but not supersede or replace any previous consents you may have provided to us. It also does not affect any legal rights we may have concerning the collection, utilization, and/or disclosure of your personal data. We reserve the right to periodically update this Policy to ensure its alignment with our future developments, industry trends, and any alterations in legal or regulatory requirements. In accordance with your legal rights, the terms outlined in this Policy will remain in effect. To avoid any confusion, this Policy is an integral part of the terms and conditions that govern your association with us and should be reviewed alongside such terms and conditions.

We prioritize the security of your personal data. Throughout the stages of data collection, utilization, and disclosure, we have implemented physical, electronic, administrative, and procedural safeguards to safeguard the personal data under our custody. However, it is essential to acknowledge that no transmission of personal data over the internet can be guaranteed to be completely secure. Despite our best efforts, we cannot provide assurance or warranty regarding the security of any information you transmit to us or from our online services. We disclaim any responsibility or liability for the security of information transmitted through the internet.

This Policy elucidates how we may collect, utilize, disclose, process, and oversee your personal data. It is applicable to the personal data of any individual that is within our possession or under our control.

What personal data is collected by us?

The term “personal data” refers to information, whether accurate or not, about an individual that can be used to identify them either directly from that information or in combination with other data to which the organization has or is likely to have access. Here are some examples of personal data that we may collect:

Personal Particulars:

Legal name

Alias(es)

Gender

Telephone number

Residential address

Date of birth

Identity card/passport details

Online Account Information:

Email address

Account username

Account password

Social media or messaging platform handles (e.g., Discord)

Other social media or messaging platform profile information

Digital Asset Details:

Information or details regarding digital assets held

Digital Wallet Information:

Particulars of digital wallet addresses (including transactions performed by these addresses)

Public cryptographic key related to digital wallet addresses on distributed ledger networks

Similar information related to digital wallets

Usage Information:

Information about your use of our services and website specific user interactions with the Website, such as features utilized, areas visited or clicked on, and time spent

Technical Data:

Usernames and passwords

Third-party account credentials (e.g., Facebook login credentials, Google login credentials)

Internet Protocol (IP) address

Geographical location

Browser type and version

Operating system used

Internet service provider

Referrers (websites from which users reach our website)

Mobile device ID

Location of access

Other similar data and information

Behavioral Data:

Pages (including sub-pages) visited

Time and date of your visit

Time spent on each page

Other diagnostic data

Personal Opinions:

Personal opinions made known to us (e.g., feedback or responses to surveys)

This personal data is automatically collected when you interact with our services, access the Website, engage with other users of our services, participate in beta/testing services, play our games, enter our tournaments, prize draws, or competitions, open emails from us, fill out forms or surveys, register or update a user account, contact us through various channels (e.g., live chat, email, social media, messaging platforms), attend in-person events, opt-in to receive marketing messages, or subscribe to our mailing lists. Additionally, to the extent permitted by law, we may obtain other information about you, such as contact information, changes of address, or demographic data, from commercially available sources.

Personal data and the Blockchain

Blockchain technology, often referred to as distributed ledger technology (DLT), forms the foundation of our operations. Blockchains are decentralized networks comprised of digitally recorded data organized into a chain of blocks. These blocks are linked chronologically, making it extremely challenging to modify data once it’s recorded. The uniqueness of blockchains lies in their global distribution, where multiple “nodes” replicate the ledger. Consequently, there’s no single entity with decision-making authority or administrative control (such as a cloud computing operator), and there’s no centralized location where the blockchain is housed.

By design, a blockchain’s data is considered “immutable,” meaning it cannot be altered or deleted. This immutability can impact your ability to exercise certain rights, such as the “right to be forgotten” or rights to object or restrict the processing of your personal data. Data on the blockchain cannot be erased or modified. Although smart contracts can be employed to revoke specific access rights and make certain content invisible to others, deletion is not possible.

In specific scenarios, to fulfill our contractual obligations to you (such as delivering tokens or providing other services), it may be necessary to collect particular personal data, like your wallet address, onto the blockchain. This process is executed through a smart contract and requires you to perform transactions using your wallet’s private key.

Ultimately, the decisions to (a) transact on the blockchain using your wallet address and (b) share the public key related to your wallet address with anyone, including us, are entirely within your control. IF YOU WISH TO ENSURE THAT YOUR PRIVACY RIGHTS REMAIN UNAFFECTED, YOU SHOULD AVOID ENGAGING IN BLOCKCHAIN TRANSACTIONS, AS CERTAIN RIGHTS MAY NOT BE FULLY AVAILABLE OR EXERCISABLE BY YOU OR US DUE TO THE TECHNOLOGICAL INFRASTRUCTURE OF THE BLOCKCHAIN. IT’S IMPORTANT TO NOTE THAT THE BLOCKCHAIN IS PUBLICLY ACCESSIBLE, AND ANY PERSONAL DATA SHARED ON THE BLOCKCHAIN WILL BECOME PUBLICLY AVAILABLE.

Specifically, information regarding your digital wallet addresses, including transactions associated with these addresses, and public cryptographic keys linked to digital wallet addresses on distributed ledger networks, or similar information used to access the Website, will be connected to your user account. By utilizing our services, you grant consent for our services to access and retrieve information from such digital wallet addresses to verify ownership of any digital assets or tokens associated with those addresses, whether they are fungible or non-fungible. Users will have the ability to “add” or “remove” their digital wallet addresses for accessing our services. All data obtained by us concerning your digital wallet addresses will be treated as personal data and managed in accordance with the provisions outlined in this Policy.

Purposes for the Collection, Use, and Disclosure of Your Personal Data

We collect, use, and/or disclose your personal data for various legitimate interests and business purposes, which encompass the following activities:

Developing, providing, and enhancing our products and services, including:

Offering a MMORPG metaverse gaming ecosystem.

Providing community support, user support, and facilitating interactions among users.

Acting as intermediaries through various blockchains, networks, or platforms.

Recording and encrypting data on blockchains, networks, or platforms.

Promoting advertisements or marketing materials, whether from us or third parties.

Offering various products and services, whether digital or physical, and whether provided by external service providers or otherwise.

Providing escrow, courier, anti-counterfeiting, cyber-security, or dispute resolution services.

Handling transactions, clearing or reporting on these transactions.

Conducting research, planning, analytics, troubleshooting, technical maintenance, and bug fixes.

Communicating with you, which includes:

Providing updates regarding changes to services or products offered by us or through us. This includes information about additions, expansions, suspensions, replacements, and any changes to the terms and conditions associated with these services or products.

Addressing, investigating, or responding to:

Feedback, queries, complaints, claims, or disputes related to our services.

Compliance with applicable laws and regulations:

Adhering to all relevant local and foreign laws, regulations, rules, directives, orders, instructions, and requests from authorities. This includes regulatory, governmental, tax, law enforcement, or other authorities.

Enforcing obligations and protecting our rights:

Ensuring the enforcement of obligations owed to us. Safeguarding our rights and property. Protecting against legal liability.

Seeking professional advice:

Seeking legal or tax advice from professionals when necessary.

Additionally, personal data may also be used for purposes outlined in the terms and conditions that govern our relationship with you or our customers.

Electronic Know-Your-Client (eKYC)

For specific product offerings, we may engage and authorize certain third-party service providers specializing in electronic know-your-client (eKYC) services for identity verification, processing of identity documentation, collection of due diligence documentation, and/or transaction monitoring.

Under these arrangements, personal data may be shared with these eKYC service providers through the submission of information, forms, documents, or media files, uploaded to online platforms operated by these service providers. The eKYC process may involve automation, semi-automation, or human intervention.

The outcomes of the eKYC process, along with all personal data provided to eKYC service providers, will be exclusively accessible to us and will not be shared with any external parties. All eKYC service providers will be required to ensure the security and robustness of the eKYC solution to safeguard personal data from unauthorized access, use, and disclosure at all times.

Use of Personal Data for Marketing Purposes

We may utilize your personal data to offer you products or services, including special offers, promotions, contests, or entitlements that may align with your interests or eligibility. These marketing communications may be delivered through various channels, such as electronic mail, direct mailers, short message service, telephone calls, facsimile, and other mobile messaging services. They may originate from us directly or from third parties with whom we collaborate. In the process, the sender will adhere to all applicable data protection and privacy laws.

Regarding telemarketing messages sent to your telephone number via short message service, telephone calls, facsimile, and other mobile messaging services, please rest assured that we will only do so if we have obtained your clear and unambiguous consent in writing or other recorded forms, or if you have not registered that number with the Do Not Call Registry. In cases where we have an ongoing relationship with you and you have not indicated your preference to opt out of receiving telemarketing messages to your telephone number, we may send you telemarketing messages related to the subject of our ongoing relationship via short message service, facsimile, and other mobile messaging services (excluding voice or video calls).

You have the option to request that we cease contacting you for marketing purposes via specific modes or all available modes.

For more information on how you can modify the way we utilize your personal data for marketing purposes, please get in touch with us.

Please note that nothing in this Policy shall alter or supersede the terms and conditions that govern our relationship with you.

Disclosure and Sharing of Personal Data

In compliance with all applicable data privacy laws, we may, on occasion, disclose your personal data to any of our personnel, staff, employees, officers, group entities, or third parties. These third parties may include banks, financial institutions, credit card companies, credit bureaus, along with their respective service providers, insurance and/or reinsurance companies, associations of insurance companies, agents, contractors, or third-party service providers who offer services such as telecommunications, information technology, payment processing, data processing, storage, archival, and our professional advisers such as auditors and lawyers, as well as regulators and authorities. Such disclosures may occur in any jurisdiction to fulfill the purposes outlined above.

Please rest assured that when we share your personal data with these parties, we will only disclose the necessary personal information required to provide the relevant services. We will also mandate these parties to maintain the confidentiality and security of any personal data disclosed to them.

For detailed information regarding the third parties with whom we share your personal data, you may refer to the agreement(s) and/or terms and conditions governing our relationship with you or our customer, where applicable. Alternatively, you can reach out to us for more information (please see section 11 below).

We want to emphasize that we do not sell personal data to third parties without your explicit consent. We are committed to full compliance with any duty or obligation of confidentiality imposed on us under the applicable agreement(s) and/or terms and conditions governing our relationship with you or our customer or any applicable law.

It is your responsibility to ensure that the personal data you provide to us is accurate, complete, and not misleading, and that such data is kept up to date. Failure to do so may result in our inability to provide you with the products and services you have requested. To update your personal data, please contact us (please see section 11 below for contact details). When you provide us with personal data about individuals other than yourself, you are responsible for obtaining all legally required consents from the concerned individuals, and you should retain proof of such consent(s) in case we request it.

We may transfer, store, process, and/or manage your personal data in any jurisdiction. Consequently, your personal data may be transferred to computers, servers, or hardware located outside your state, province, country, or other governmental jurisdiction, where data protection laws may differ from those in your jurisdiction. We will take all reasonable steps to ensure that your data is treated securely and in line with this Policy. No transfer of your personal data will occur to an organization or country unless adequate controls are in place, including data security measures and compliance with data protection laws (including, but not limited to, the Standard Contractual Clauses approved by the European Commission). Your consent to this Policy, followed by your submission of such information, signifies your agreement to the transfer of personal data as described herein.

Cookies and Related Technologies

The Website utilizes cookies, which are small text files placed on your computer or mobile device when you visit a Website or use an app. These cookies may include an anonymous unique identifier and collect information about users and their interactions with the Website or app. The information collected may encompass the user’s Internet protocol (IP) address, the method by which they accessed the Website (e.g., through a search engine or a link from another Website), their navigation within the Website or app, browser information, computer or device type, operating system, internet service provider, website usage, referring/exit pages, platform type, date/time stamp, number of clicks, ads viewed, and how they utilize our services.

We employ cookies and related technologies for various purposes, including facilitating internet sessions and app usage, tailoring products and services to user preferences, displaying features and services that may be of interest (including advertisements), monitoring website and app usage, compiling statistical data about activities on our websites, and storing specific information.

Examples of cookies we use include:

Sign-in and Authentication Cookies: These enable user authentication.

Session Cookies: These are essential for operating our service.

Preference Cookies: They remember user preferences and settings.

Third-Party Cookies: Obtained from third-party services to incorporate external data.

Security Cookies: Utilized for security purposes.

You have the option to configure your web browser to block cookies from tracking your website visit or remove stored cookies from your computer or mobile device. However, blocking cookies may limit your ability to use certain features and functions of our Website.

Additionally, we employ various tracking technologies provided by third parties like Google Tag Manager, Google Analytics, hCaptcha, FeedBucket, Notifi, and Raleon Analytics. These technologies include cookies, mobile device identifiers, beacons, tags (including pixel tags), and scripts to collect and track information and enhance the analysis of our services.

Please note that our systems may not fully recognize “do not track” signals or other mechanisms that allow users to opt out of tracking on the Website. We provide users with the option to disallow cookies, which will disable all cookies except for essential ones (e.g., cookies used directly for service provision or basic statistical tracking). If a user chooses not to allow cookies, they may not access certain Website features or services.

Other Websites

Our websites may include links to third-party websites that are not maintained by us. This Policy exclusively pertains to websites maintained by us. When visiting these third-party websites, we strongly recommend reviewing their privacy policies, which will govern your use of those websites.

Retention of Personal Data

We retain your personal data as long as it serves the purpose for which it was collected and remains necessary for legal or business reasons. This retention allows us to comply with legal and regulatory obligations or utilize the data for legitimate purposes, such as digital asset transfers and addressing any disputes or concerns.

There may be instances where we must retain information for an extended period, either to fulfill regulatory or legal requirements or for our legitimate interests (e.g., responding to queries or complaints, combating fraud and financial crime, addressing regulator requests, etc.).

When we no longer require personal data for our purposes, we will either delete it from our systems and records or take measures to anonymize it to the extent that it can no longer identify you.

Queries, Access/Correction Requests, and Withdrawal of Consent

If you have:

Inquiries about our data protection procedures and practices; Requests for access to and/or corrections of your personal data in our possession or control; or The desire to withdraw your consent for our collection, use, or disclosure of your personal data,

Please submit a written request, along with any supporting documents, to our Data Protection Officer at privacy@larkena.com.

Our Data Protection Officer will respond to your request within 30 days of its submission. Please note that depending on the nature of your request, withdrawing consent may impact our ability to provide services or products to you or manage any existing contractual relationships. In such cases, the termination of agreements may occur, and our legal rights and remedies will remain intact.

Processing fees may apply for access requests, depending on their nature and complexity. Details about these fees will be provided to you.

Contact Information

For any questions related to this Policy, your personal data, or feedback, please contact our Data Protection Officer at privacy@larkena.com.

We value your privacy and aim to address any concerns or inquiries promptly.

Governing Law and Jurisdiction

This Policy and your use of the Website are governed and construed in accordance with the laws of Singapore. Any disputes arising from or in connection with this Policy, including questions regarding its existence, validity, or termination, as well as your access or use of the services, shall be referred to and finally resolved through arbitration administered by the Singapore International Arbitration Centre (SIAC). The arbitration will be conducted in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (SIAC Rules) in effect at the time. The arbitration will take place in Singapore, and a single arbitrator will preside over the proceedings. The language of the arbitration will be English. The arbitrator’s award will be conclusive and binding, and any judgment based on the award may be entered in any competent court. Each party consents to the jurisdiction and venue of this tribunal. Additionally, each party will bear its own fees and costs related to the arbitration proceedings.

Amendments and Updates to Larkena’s Privacy Policy

We reserve the right to modify this Policy periodically to align it with changes in the way we handle your personal data or updates in relevant laws and regulations. The updated Policy will be made available on the Website. We encourage you to visit the Website regularly to stay informed about our latest policies related to personal data protection. All communications, transactions, and interactions with us are subject to the most recent version of this Policy in effect at the time.

For European Union or European Economic Area Residents

This section 14 applies if you are an individual located in the European Union or European Economic Area (EU/EEA). In accordance with applicable law, you have the following additional rights regarding your personal data:

The right to access your personal data: If you request it, we will confirm whether we are processing your personal data in a structured, commonly used, and machine-readable format and, if so, provide you with a copy of that personal data, along with specific details. Additional copies may be subject to a reasonable fee.

The right to ensure the accuracy of your personal data.

The right to request the deletion of your personal data (in certain circumstances, such as when it is no longer necessary, but note that we may not delete your data if other interests outweigh your right to deletion).The right to restrict further processing of your personal data (unless we demonstrate compelling legitimate grounds for processing).Rights related to automated decision-making and profiling (you have the right to be free from decisions solely based on automated processing, including profiling, unless necessary for a contract between you and us or with your explicit consent).The right to withdraw your consent (if we rely on your consent for processing, you can withdraw it at any time, but this won’t affect the lawfulness of processing based on prior consent).The right to lodge a complaint with a supervisory authority if you believe that our processing of your personal information violates data protection laws. You may do this in your EU member state of residence, place of work, or the location of the alleged violation.

You can exercise these rights in relation to your personal data by contacting our Data Protection Officer at privacy@larkena.com, and we will respond within 30 days of receiving your request.

Your Acceptance of These Terms

This Policy is applicable in conjunction with any other notices, contractual clauses, and consent clauses relevant to the collection, use, and disclosure of your personal data by us. We may update this Policy periodically without prior notice. You can check if any revisions have been made by referring to the date of the last update of this Policy.

By utilizing the Website and/or any services offered by us, you indicate your agreement with this Policy and the terms of service. If you do not agree with this Policy or the terms of service, please refrain from using the Website or any services provided by us. Your continued use of the Website after changes to this Policy have been posted will be considered as your acceptance of those changes.