Privacy Policy

Last Updated: 8th September 2021

Your privacy is important to us. This privacy statement explains the personal data TokenRunway processes, how TokenRunway processes it, and for what purposes. Please read the product-specific details in this privacy statement, which provide additional relevant information. This statement applies to the interactions TokenRunway has with you. This statement is a part of our Terms of Use (“TOU”) and is in addition to its stipulations.

We will update this Privacy Statement when necessary to reflect customer feedback and changes in our products and services. When we post changes to this statement, we will revise the “last updated” date at the top of this Statement.

Who does this Statement apply to: This Privacy Statement applies to personal data collected by TokenRunway in connection with the services and products we offer. References to “TokenRunway” in this Statement means Trailblaze Productions Private Limited and any company directly or indirectly owned and/or controlled by Trailblaze Productions Private Limited that you are interacting with or have a business relationship with. This Privacy Statement also applies to TokenRunway’s marketing content, including offers and advertisements for TokenRunway products and services, which we (or a service provider acting on our behalf) send to you on third-party websites, platforms and applications based on your site usage information. These third-party websites generally have their own Privacy Notice and Terms and Conditions. We encourage you to read them before using those websites.

What we mean by Personal Data: We collect data from you to operate efficiently and to provide you with the best possible services. Personal data is a type of this data, which can directly or indirectly lead to the identification of a specific person. This definition includes personal data collected offline through our Consumer Engagement Centres, direct marketing campaigns, sweepstakes and competitions and online through our websites, applications and branded pages on third-party platforms and applications accessed or used through third-party platforms.

What Personal Data We Collect

You are not required to provide TokenRunway the personal data that we request, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have.

You may be asked to provide your personal data when you are in contact with us. TokenRunway may share your personal data with other entities owned and/or controlled by Trailblaze Productions Private Limited and use it in a manner consistent with this Privacy Statement. We may also combine it with other information to improve our products, services, content, and advertising.

Sources

We may collect your personal data from the following sources:

  1. Personal data you give us directly: We collect data about how you use our services and products, such as the types of content you view or engage with, or the frequency and duration of your activities. We also collect personal data you provide us when you sign up for a marketing newsletter, complete a survey or register for a third-party account to buy our products (if they share that data with us under their Privacy Notice). In so doing, we may ask for personal data, such as your name, gender, date of birth, address, email address, or telephone number.
  2. Personal data we collect automatically: We also receive and store certain types of personal data whenever you interact with us online. For example, we use cookies and tracking technologies to obtain personal data when your web browser accesses our websites or advertisements and other content served by or on behalf of TokenRunway on other websites. Your personal data is also collected when you search, buy, post, participate in a contest or questionnaire or communicate with our customer service teams. Examples of the types of personal data we collect include; IP address, device ID, location data, computer and connection information such as browser type and version, time zone setting, browser plug-in types and versions, operating system, and purchase history – which TokenRunway sometimes aggregates with similar information from other consumers. During some of your internet browsing on TokenRunway’s websites we may also use software tools to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information, and methods used to browse away from the page. We may also collect technical information to help us identify your device for fraud prevention and diagnostic purposes.
  1. Personal data we collect from other sources: We collect personal data from other sources including our trusted partnerships with third-parties and where we operate TokenRunway accounts on third-party platforms: For example, when you purchase a Non-Fungible Token (NFT) listed by us on an authorised third-party marketplace. Additionally, we may receive information about you and other visitors’ interactions with our advertising to measure whether our advertising is relevant and successful. We also collect information about you and your activities from a third-party when we jointly offer services or products, or from third-party data enrichment providers who may deliver insights to TokenRunway about the personal data we hold.

Children

We understand the importance of taking extra precautions to protect the privacy and safety of children using TokenRunway products and services.

TokenRunway’s websites are designed and intended for use by adults. If you are a child under the age where parental consent is required in your Country, you should review the terms of this Privacy Statement with your parent or guardian to make sure you understand and accept them. If we discover that we have collected personal data from a child without consent from a parent or guardian where such consent should have been obtained, we will delete that personal data as soon as practical. Access to certain parts of the TokenRunway’s websites and/or eligibility to receive prizes, samples or other rewards are generally limited to users over a certain age.

What Purpose We Use Your Data For

We collect, process and disclose your personal data only for specific and limited purposes. For example, to assess and handle any complaints, to develop and improve our products, services, communication methods and the functionality of our websites, to provide personalised products, communications and targeted advertising as well as product recommendations to you.

Additionally, TokenRunway processes your personal data also using automated means. An automated decision is a decision which is made solely by automatic means, where no humans are involved in the decision-making process related to your personal data.

We collect, process and disclose your personal data for the following purposes:

  1. To process and answer your inquiries or to contact you to answer your questions and/or requests;
  2. To develop and improve our products, services, communication methods and the functionality of our websites;
  3. For the purposes of competitions or promotions that you have entered;
  4. To communicate information to you and to manage your registration and/or subscription to our newsletter or other communications;
  5. To manage our everyday business needs regarding your participation in our contests, sweepstakes or promotional activities or request;
  6. To authenticate the identity of individuals contacting us by telephone, electronic means or otherwise;
  7. For internal training and quality assurance purposes;
  8. To understand and assess the interests, wants, and changing needs of consumers, to improve our website, our current products and services, and/or developing new products and services; and
  9. To provide personalised products, communications and targeted advertising as well as product recommendations to you.

Legitimate Interest: In some cases, we rely on legitimate interest for processing your personal data. A legitimate interest could exist for example, when you sign up for a loyalty scheme with one of our brands and we use the personal data collected to conduct data analytics to improve our products or services. This ground will only be used where it is necessary to achieve a legitimate interest, for example to assist in the performance of a contract, or to optimise a service, and does not outweigh your rights as an individual. This legal basis will only be relied upon where there is no less intrusive way to process your personal data. We can assure you that if legitimate interest is used as a ground for processing your personal data, we will keep a record of this and you have the right to ask for this information.

Perform Contract: We process your personal data to perform a contract to which you are or will be a party. For example, we need to process your personal data to deliver a product or a service you bought, to allow you to take part in one of our competitions, etc.

Legal Obligation: We also process your personal data when we have a legal obligation (e.g. Police asking for information we are legally bound to provide) to perform such processing.

Profiling: TokenRunway uses your personal data to build profiles. We create profiles by analysing the information about your online surfing, searching and buying behaviour and your interactions with our brand communications by building segments (creating groups that have certain common characteristics) and by placing your personal data in one or more segments. These segments are used by TokenRunway to personalise the website and our communications to you (such as showing relevant content to you when you visit our site or in a newsletter to you), and to display relevant offers and advertisements from the TokenRunway brands on the TokenRunway sites, and via third-party websites. The segments can also be used for third-party campaigns on the TokenRunway sites. TokenRunway profiles your data where you have provided consent for us to do so; for example, accepting the setting of cookies on your browser online or signing up for email newsletters from one of our brands.

Data Sharing

TokenRunway shares your personal data with entities owned and/or controlled by Trailblaze Productions Private Limited and with selected third-parties in the following circumstances:

  1. Third-party service providers: In order to carry out your requests, respond to your inquiries, fulfil your orders, honour coupons, provide you with samples, enable you to participate in sweepstakes or make various other features, services and materials available to you through our websites we share your personal data with third-party service providers that perform functions on our behalf, such as companies that: host or operate TokenRunway’s websites, analyse data, provide customer service, postal or delivery services, and sponsors or other third-parties that participate in or administer our promotions. They have access to personal data needed to perform their functions but may not use it for other purposes. Further, they must process this personal data in accordance with this Privacy Statement and as permitted by applicable data protection laws and regulations.
  2. Other third-parties: Your personal data will also be used by us or shared with our sponsors, advertisers, advertising networks, advertising servers, social media networks, and analytics companies or other third-parties in connection with marketing, promotional, data enrichment (to find out more about our privacy key terms follow the link) and other offers, as well as product information.
  3. Business transfers: Your personal data will be used by us or shared with entities owned and/or controlled by Trailblaze Productions Private Limited, primarily for business and operational purposes. As entities owned and/or controlled by Trailblaze Productions Private Limited continues to develop the business, it may sell or purchase assets, subsidiaries or business units. In such transactions, your personal data generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, you consent otherwise). If another entity acquires us, our businesses or substantially all or part of our assets, or assets related to TokenRunway’s websites, your personal data will be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such personal data will be considered an asset of ours and as such it is possible they will be sold or transferred to third-parties.
  4. Legal disclosure: We may transfer and disclose your personal data to third-parties:
    1. To comply with a legal obligation;
    2. When we believe in good faith that an applicable law requires it;
    3. At the request of governmental authorities conducting an investigation;
    4. To verify or enforce our “Terms of Use” or other applicable policies;
    5. To detect and protect against fraud, or any technical or security vulnerabilities;
    6. To respond to an emergency; or otherwise
    7. To protect the rights, property, safety, or security of third-parties, visitors to TokenRunway’s websites, TokenRunway or the public.

How do We Protect your Personal Data

TokenRunway takes the security of your personal data very seriously. We take every effort to protect your personal data from misuse, interference, loss, unauthorised access, modification or disclosure.

Our measures include implementing appropriate access controls, investing in the latest Information Security Capabilities to protect the IT environments we leverage, and ensuring we encrypt, pseudonymise and anonymise personal data wherever possible.

Access to your personal data is only permitted among our employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third-parties.

How Long do We Keep Your Personal Data For

We will keep your personal data for as long as we need it for the purpose it is being processed for. For example, where you make a purchase online with us we will keep the data related to your purchase, so we can perform the specific contract you have entered and after that, we will keep the personal data for a period which enables us to handle or respond to any complaints, queries or concerns relating to the purchase.

Your data may also be retained so that we can continue to improve your experience with us and to ensure that you receive any loyalty rewards which are due to you.

We retain the identifiable data we collect directly for targeting purposes for as little time as possible, after which we employ measures to permanently delete it.

We will actively review the personal data we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or consumer need for it to be retained.

Your Rights

You can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights by sending an email to info@tokenrunway.com.

Where we process your personal data, you have a number of rights over how the data is processed and can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights by sending an email or submitting a request through the “Contact Us” form on our websites.

  1. The right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. Therefore, we’re providing you with the information in this Notice.
  2. The right to access and rectification: You have the right to access, correct or update your personal data at any time. We understand the importance of this and should you want to exercise your rights, please contact us.
  3. The right to data portability: The personal data you have provided us with may be portable. This means it can be moved, copied or transmitted electronically under certain circumstances.
  4. The right to be forgotten: Under certain circumstances, you have right to request that we delete your data. If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements. If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it.
  5. The right to restrict processing: Under certain circumstances, you have the right to restrict the processing of your personal data.
  6. The right to object: Under certain circumstances, you have the right to object to certain types of processing, including processing for direct marketing (i.e., receiving emails from us notifying you or being contacted with varying potential opportunities).
  7. The right to lodge a complaint with a Supervisory Authority: You have the right to lodge a complaint directly with the relevant Supervisory Authority about how we process your personal data.
  8. The right to withdraw consent: If you have given your consent to anything we do with your personal data (i.e., we rely on consent as a legal basis for processing your personal data), you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your personal data at any time by contacting us with the details provided below.

Cookies

Acceptance: By using our websites, you are consenting to our use of cookies in accordance with this Cookie Notice and our Privacy Statement. If you do not agree to our use of cookies in this way, you should set your browser settings accordingly, disable the cookies that we use or not use our websites at all. If you disable the cookies we use, this may impact your user experience while on the websites. TokenRunway will only collect, use or disclose your personal data where it is fair and lawful to do so.

What are Cookies: Cookies, pixel tags and similar technologies (collectively ‘cookies’) are files containing small amounts of information which are downloaded to any internet enabled device – such as your computer, smartphone or tablet – when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies do lots of different and useful jobs, such as remembering your preferences, generally improving your online experience, and helping us to offer you the best product and services.

Purpose

We use cookies to make TokenRunway websites easier to use, to deliver a personalised experience on our websites, and to better tailor our products, services and websites to your interests and needs. Cookies are used to help speed up your future activities and your experience on TokenRunway websites.

The cookies you consent to, are also used to collect your personal data which we then profile into audiences so that we can deliver targeted advertising tailored to your interests and limit the number of times you see an advertisement. For more detailed information about the profiling activities TokenRunway undertakes with your personal data for advertising, please see our Privacy Statement.

We insert cookies in emails and newsletters to improve our content and advertising. We also use cookies to compile anonymous, aggregated statistics that allow us to understand how people use our websites and to help us improve their structure and content and also help us measure the effectiveness of advertising campaigns on TokenRunway and non-TokenRunway websites.

Manage Your Preferences

Most internet browsers are initially set up to automatically accept cookies. If you do not want our websites to store cookies on your device, you can change your browser settings so that you receive a warning before certain cookies are stored. You can also adjust your settings so that your browser refuses most of our cookies or only certain cookies from third parties. You can also withdraw your consent to cookies by deleting the cookies that have already been stored.

If you disable the cookies that we use, this may impact your experience while on the TokenRunway website, for example you may not be able to visit certain areas of a website or you may not receive personalized information when you visit a website.

If you use different devices to view and access the TokenRunway website (e.g., your computer, smartphone, tablet) you will need to ensure that each browser on each device is adjusted to suit your cookie preferences.

The procedures for changing your settings and cookies differ from browser to browser. Please check with your browser FAQs for understanding how to do so.

Contact

For any queries, issues, concerns, complaints, or questions, please contact:

Address – Trailblaze Productions Private Limited, 1005, Mohini Heights, 5th Road, Khar West, Mumbai, Maharashtra, 400052, India.

Email – vinay@trailblaze.productions