PRIVACY POLICY

The term "personal data" means any information by which a natural person can be identified, directly or indirectly.

The term "data controller" means the natural or legal person which, alone or jointly with others, determines the purposes and means of the data processing and is responsible for processing such data in a manner consistent with the applicable legislation.

The term "data processor" means the natural or legal person which processes personal data on behalf of a data controller.

Tribute Brand companies, hereinafter “we” or Tribute Brand, (Tribute Brand Inc.-USA, YCY d.o.o.-Croatia and Tribute Holding Limited Cayman-Cayman Islands) are joint data controllers of your personal data based on joint controllership agreement between affiliated companies.

Information sharing and usage
When you use our online services (our website and app), you’ll share some information with us. We want to be transparent with the data we collect, how we use it, whom we share it with, and the controls we give you to access, update, and delete your information.

There are three basic categories of information we collect:

* Information you provide.

* Information we get when you use our services.

* Information we get from third parties.

Categories explained
When you interact with our services, we collect information that you provide to us. For example, most of our services require you to set up an account, so we need to collect a few important details about you, such as your username, password, and email address, from which we may conclude information about your name and surname and gender.

We may also ask you to provide us with some additional information that will be publicly visible on our services, such as a profile picture. Other services, such as commerce products, may require you to provide us with a debit or credit card number and its associated account information, such as IP address of your device, purchases, phone number and billing/delivery address.

Within the project Punk and regarding NFT products we process data about your public address and wallet information. Your account information will be associated with blockchain public address and display NFTs.

Of course, you’ll also provide us whatever information you send through our services, such as images and videos.

When you contact customer support or communicate with us in any other way, we’ll collect whatever information you provide or that we need to resolve your question/issue.

Information We Get When You Use Our Services
When you use our services, we collect information about which of those services you’ve used and how you’ve used them.

We collect information about your activity through our services. For example, we may collect information about how you interact with our services, such as which digital items you view or apply via AR camera or which search queries you submit.

We collect content you create on our services and information about the content you create or provide.

While the app is running, we use following information:

* information about your hardware and software, such as the hardware model, operating system version, device memory, browser type, language, battery level, and time zone;

* information about your wireless and mobile network connections, such as mobile phone number, service provider, IP address, and signal strength.

* our services require us to collect images and other information from your device’s camera and photos. For example, you won’t be able to send or upload photos from your camera roll unless we can access your camera or photos.

This information is not collected and stored on our servers. We use data anonymising techniques and services, such as, Firebase Crashlytics and Apple Developer App analytics.

Log Information
We also collect log information when you use our website, such as:

* details about how you’ve used our services;

* device information, such as your web browser type and language;

* access times;

* pages viewed;

* IP address;

* identifiers associated with cookies or other technologies that may uniquely identify your device or browser; and pages you visited before or after navigating to our website.

How We Use Information
What do we do with the information we collect:

* Develop, operate, improve, deliver, maintain, and protect our products and services.

* Send you communications, including by email. For example, we may use email to respond to support inquiries or to share information about our products, services, and promotional offers that we think may interest you.

* We process data regarding opening e-mails, bounce rate, clicks, subscription, news segments. We may segment buyers according to previously bought products, and country.

* If you contact us through webforms on our website, through an e-mail, phone, or social network profile we will process data from contact form and a message based on our legitimate interest to connect and communicate with potential customers.

* We process data about our contacts on social networks and about likes, comments, profile information, picture, video, voice, and about similar communication with our customers and potential customers.

* Monitor and analyse trends and usage.

* Personalize our services.

* Enhance the safety and security of our products and services.

* Verify your identity and prevent fraud or other unauthorized or illegal activity.

* Use information we’ve collected from cookies and other technology to enhance our services and your experience with them.

* Enforce our Terms of Service and other usage policies and comply with legal requirements.

* Perform daily business activities, such as, planning, controlling, auditing, organising business processes in all our affiliated companies and maintain compliance with applicable laws.

* We may also use information from Apple’s TrueDepth camera to improve the quality of AR Shells. Information from the TrueDepth camera is used in real time—we don’t store this information on our servers or share it with third parties.

Cookies
Cookies are small text files that we place on your device (e.g. computer or mobile device) when you visit our website. We will always ask your consent to set cookies e.g., to remember your preferences or personalize content that is more relevant to you. However, we won’t ask your consent for cookies that are strictly necessary for specific functionalities of our services, i.e. without which you wouldn’t be able to undertake certain activities.

Necessary Cookies. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information. Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

Preferences Cookies. Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.

Analytics/Statistics Cookies. These cookies allow us to count visits, usage and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information collected by these cookies is aggregated and anonymized. If you do not allow these cookies we will not know when you have visited our site, what features of the web site you interacted with and will not be able to monitor its performance.

Marketing/Advertising Cookies. These cookies are set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and Internet device. If you do not allow these cookies, you will get a less tailored experience. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.


Managing Cookies. When you first visit our website, you will see our Cookie Declaration/Banner where you can accept all the cookies or manage your cookie settings. You can withdraw your consent at any time.

Information about procedure on how to enable, disable or remove cookies can be found on your Internet browser provider’s website via your help screen. If you wish to learn more on this matter, we invite you to visit the following address:https://www.youronlinechoices.com.

Links to popular browsers are listed below for your convenience. Some of the listed browsers block third party cookies by default. For other browsers, please consult your browser settings for managing cookies.

* Google Chrome

* Microsoft Edge

* Mozilla Firefox

* Microsoft Internet Explorer

* Opera

* Apple Safari

We use third party cookies to optimize marketing performance and to measure the effectiveness of our advertising on other websites and social networks.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

If you elect not to activate the cookies, or later to disable cookies, you may still visit our website, but your ability to use some features or areas of the website may be limited.

For more details regarding privacy and personal data protection on social networks, please read:

* INSTAGRAM Manage cookies on Instagram

* TWITTER Manage Cookies with Your Ad Choices

* LINKEDIN Manage cookies with LinkedIn Ad Settings

* DISCORD Manage privacy settings on Discord

* TIKTOK Manage cookies with TikTok

* SNAPCHAT Manage privacy on Snapchat

* KakaoTalk Manage privacy on KakaoTalk

HOW WE SHARE INFORMATION/DATA
We may share information about you, your personal data, in the following ways:

With other Tribute App users. We share the following information with other Tribute App users:

* information about you, such as your username and photo.

* any additional information you have directed us to share. For example, Tribute App will share your information when you connect your Tribute App account to a third-party app, and if you share information or content from Tribute App to the third-party app.

* content you post or send. How widely your content is shared depends on your personal settings and the type of service you are using.

* With all Tribute App users, our business partners, and the public. We share the following information with all Tribute App users as well as with our business partners and the public:

* public information, for example your username.

With third parties:

* Business partners that provide services and functionality on our services.

* With affiliated companies for commercial and financial activities and on the basis of purposes that are in connection with the selection, entering into, handling and performance of trading or contractual relationships, for the administrative management of the agreements including for handling payments and invoices, for the receipt of goods and/or services, for handling litigation (if existing), for the purposes of internal group reporting, for internal audit purposes and for the management control purposes.

* For transactions regarding NFTs we use service of our affiliated company YCY d.o.o., Ksajpa 2A, Šenkovac, Croatia and third party services Paper.xyz and Nilos.io.

* We share information about you for legal, safety, and security reasons. We may share information about you if we reasonably believe that disclosing the information is needed to:

* investigate, remedy, or enforce potential terms of service violations.

* protect the rights, property, or safety of us, our users, or others.

* detect and resolve any fraud or security concerns.

* We may share information about you as part of a merger or acquisition. If Tribute Brand companies get involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after the transaction closes.

* We may also share with third parties that provide services to us or perform business purposes for us aggregated, non-personally identifiable, or de-identified information.

* We process personal data for marketing purposes when you subscribe to our newsletter, or you purchase our products. For this purpose, we process data, such as, name, surname, country, email address and we send our newsletter by using Mailchimp services.

* We maintain our server on Discord and for this purpose we do not store the data. Please read how Discord processes your personal data.

DATA RETENTION
* We store your basic account information—like your name, phone number, photo uploads and email address—and list of friends until you request to delete them.

* If you ever decide to stop using Tribute App, you can just ask us to delete your account. We’ll also delete most of the information we’ve collected about you after you’ve been inactive for a while—but don’t worry, we’ll try to contact you first.


Keep in mind that, while our systems are designed to carry out our deletion practices automatically, we cannot promise that deletion will occur within a specific timeframe. We will keep your profile information for several months after the deletion, as deactivated account. There may be legal requirements to store your data for a longer period and we may need to suspend those deletion practices if we receive valid legal process asking us to preserve content, if we receive reports of abuse or other terms of service violations, or if your account or content created by you is flagged by our automated systems for abuse or other terms of service violations. After these timeframes, your personal data will be deleted or anonymised.

In any case you can object to direct marketing activities, and you may unsubscribe from our newsletter by clicking the link in our email or responding to us with your claim. In such case we will stop with marketing activities and store your data in unsubscribed list for three years from the day of unsubscribing, based on our legitimate interest to prove facts on compliance steps we need to take.

Finally, we may also retain certain information in backup for a limited period or as required by law and security reasons.

CONTROL OVER YOUR INFORMATION/DATA
We want you to be in control of your information, so we provide you with the following tools.

* Access, Correction, and Portability. You can access and edit most of your basic account information right in our app. Because your privacy is important to us, we will ask you to verify your identity or provide additional information before we let you access or update your personal information. We may also reject your request to access or update your personal information for several reasons, including, for example, if the request risks the privacy of other users or is unlawful.

* Revoking permissions. In most cases, if you let us use your information, you can simply revoke your permission by changing the settings in the app or on your device if your device offers those options. Of course, if you do that, certain services may lose full functionality.

* Deletion. While we hope you’ll remain a lifelong Tribute App user, if for some reason you ever want to delete your account, it is possible to do so inside the app. You can also delete some information in the app, like photos you’ve saved.


In any case you can object to our direct marketing activities, and you may unsubscribe from our newsletter by clicking the link in our email or responding to us with your claim. In such case we will stop with marketing activities and store your data in unsubscribed list for three years from the day of unsubscribing, based on our legitimate interest to prove facts on compliance steps we need to take.

SECURITY
While processing personal data, we conduct necessary technical and organisational measure. We engage appropriate data processors, and we analyse risk in case of a data breach. If a data breach results in high risk, we will notify relevant data protection authority and data subject.

SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
The California Consumer Privacy Act (“CCPA”), which is effective as of January 1, 2020, regulates how we handle personal data of California residents and gives California residents certain rights with respect to their personal data. This supplemental privacy policy shall apply only to residents of California and may be subject to change.

The general Privacy Policy shall continue to apply to the extent that it applies to you as a resident of California. If you are a resident of California, we are required to disclose certain uses and disclosures in a certain format, as well as to inform you of certain rights you may have. Any term used in this supplemental privacy policy shall have the same meaning as in the general privacy policy.

The CCPA requires disclosure of the categories of personal information collected over the past 12 months. While this information is provided in greater detail above, the categories of personal information that we have collected – as described by the CCPA – are:

* Identifiers, including name, email address, IP address, and an ID or number assigned to your account.

* Other individual records such as phone number, billing address, or credit or debit card information. This category includes personal information protected under pre-existing California law (Cal. Civ. Code 1798.80(e)) and overlaps with other categories listed here.

* Demographics, such as your age or gender, or, where you have provided such information to voluntarily. This category includes data that may qualify as protected classifications under other California or federal laws.

* Commercial information, including purchases and engagement with our services.

* Internet activity, including your interactions with our services.

* Inferences, including information about orders, interests, preferences, and favourites.


We collect and use these categories of personal information for our business and commercial purposes that are previously described, including planning and organising business activities between affiliated companies, providing and improving our services, maintaining the safety and security of our services, processing purchase and sale transactions, and for advertising and marketing services. We share personal data as described above under Sharing data with third parties.

We may access, preserve, and disclose each of the categories listed above to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

“Sales” of Personal Information under the CCPA

For the purposes of the CCPA, we do not “sell” personal information, nor do we “sell” personal information of minors.

To opt-out of receiving interest-based advertising, you can exercise your choice by using your privacy settings.

Additional Privacy Rights for California Residents

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us.

Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include contact information. We will only ask for the minimum data and only what is relevant in the given context.

RIGHTS OF ACCESS, DELETION, CORRECTION, AND PORTABILITY
You can exercise your rights of access, deletion, correction, and portability as described in the Control Over Your Information section above. You also have the right to object to data processing and right not to be subject to a decision, which may include a measure, evaluating personal aspects relating to you which is based solely on automated processing, and which produces legal effects concerning you.

You also have the right to lodge an appeal to your data protection authority.

BASES FOR PROCESSING PERSONAL DATA
We process your personal data when certain conditions apply. These conditions are called “legal bases” and we typically rely on one of four:

CONTRACT
One reason we might use your personal data is because you’ve entered into an agreement with us. For example, when you buy a digital asset and accept our terms of service, we need to use some of your personal data to collect payment and provide the service. If you don’t wish to provide your personal data, we will not be able to enter into an agreement with you.

LEGITIMATE INTEREST
Another reason we might use your information is because we have—or a third party has—a legitimate interest in doing so. For example, we need to use your personal data to provide and improve our services, including protecting your account, delivering your digital assets, communicate with you electronically, and providing customer support. An important point to understand about legitimate interest is that our interests don’t outweigh your right to data protection and privacy, so we only rely on legitimate interest when we think the way we are using your data doesn’t significantly impact your right to personal data protection and right to privacy or would be expected by you, or there is a compelling reason to do so.

CONSENT
In some cases, we’ll ask for consent to use your personal data for specific purposes, for example we ask for the consent for sending our newsletter.

If we ask for the consent, we’ll make sure you can revoke your consent in our services or through your device permissions. Even if we’re not relying on consent to use your personal data, we may ask you for permission to access data like contacts and location.

LEGAL OBLIGATION
We may be required to use your personal data to comply with the law, like when we respond to valid legal process or need to take action to protect our users. For example, when we issue an invoice or place a cookie banner on our website, we do that because we are legally obliged to do so.

YOUR RIGHT TO OBJECT
You have the right to object to our processing of your personal data. With many types of personal data, we’ve provided you with the ability to simply delete it if you don’t want us processing it anymore. For example, you always have the right to object to our legitimate interest for performing direct marketing activities and you always have the right to withdraw your consent.

For other types of data, we’ve given you the ability to stop the use of your data by disabling the feature altogether. If there are other types of personal data you don’t agree with us processing, you can contact us.

You also have the right to lodge a complaint to supervisory data protection authority (In Croatia-Croatian Data Protection Agency, onCayman Islands-Ombudsman).

INTERNATIONAL TRANSFERS
We may collect your personal data from, transfer it to, and store and process it in the other countries outside of where you live.

We are based in the United States, EU, and Cayman Islands. Therefore, we process and store information on servers in the EU and servers located in the United States. We may also store information on servers and equipment in other countries depending on a variety of factors, including the locations of our users and service providers. These data transfers allow us to provide our services to you. By accessing or using our services or otherwise providing information to us, you understand that your information will be processed, transferred, and stored in the United States and other countries, where different data protection standards may apply.

When transferring data outside the EEA, we use standard contract clauses and additional technical and organisational measures. We rely on the European Commission's adequacy decisions about certain countries, as applicable, or other legally compliant mechanisms or conditions for such data transfer.

We appointed as data protection officer and representative in the EU, our affiliated company YCY d.o.o., Ksajpa 2A, Šenkovac, Croatia.

CHILDREN
Our services are not intended for—and we don’t direct them to—anyone under 18 years old. And that’s why we do not knowingly collect personal data from anyone under 18. If we need to rely on consent as a legal basis for processing your personal data and your country requires consent from a parent, we may require your parent’s consent before we collect and use such data.

REVISIONS TO THE PRIVACY POLICY
We may change this Privacy Policy from time to time. But when we do, we’ll let you know one way or another. Sometimes, we’ll let you know by revising the date at the top of the Privacy Policy that’s available on our website and mobile application. Other times, we may provide you with additional notice (such as adding a statement to our websites’ homepages or providing you with an in-app notification).

We inform registered customers about the new version of Privacy Policy, if the changes are substantial and are not only connected with the grammar, style, corrections etc. Your continued use of any portion of our sites following the updated Privacy Policy will constitute your acknowledgment of the changes.

If you have any questions about this Privacy Policy, the personal data/information we hold from you, or you would like to exercise one of your privacy and data protection rights, please do not hesitate to contact us on hello@tribute-brand.com.