Voono Privacy Notice
Last Updated: May 2023

1. Introduction

Voono is an interactive sports entertainment platform where sports enthusiasts ("you," or "User") can engage with your favourite athletes and teams while connecting with the worldwide sports community. We prioritise your privacy and strive to create a secure space for our Users. This confidentiality statement ("Statement") aims to inform you about the collection and processing of your data by Voono ("we," "us," or "Voono"). All Personal Data (defined below) will be handled according to relevant laws, including the European Union's General Data Protection Regulation, federal and state laws in the United States governing personal data protection, and other applicable data protection regulations. This Statement is incorporated into the Terms and Conditions. Capitalised terms not explicitly defined here shall have the meaning assigned to them in the Terms and Conditions.
2. Data Collection and Objectives

We collect, store and use a limited amount of Personal Data for specific objectives, such as granting you access to the Services, enhancing the usability of the Services, improving your experience, and preventing fraud. In accordance with the UK’s Data Protection Act 2018 and the GDPR, whenever we collect your Personal Data, and for whatever reasons, we are dedicated to always collecting the least amount of Data necessary for the relevant purpose.

This section offers additional information about the types of Personal Data we collect, the processing purposes, and the legal basis for each specific processing objective.

  • Account Details. Voono collects and processes Data to enable you to create and access your User account. To manage your User account from inception to deletion, you must provide us with certain information about yourself (e.g., your first name, last name, username, email address and phone number). You can also save your personal settings, preferences, and favourite teams or players on your general User account and/or through your browser and device. Voono associates your choices with your User account, technical identifiers, browser, and/or device to store these details.

  • The legal basis for this processing is contractual. We need this data to establish and maintain your User account, execute the Terms and Conditions, and any other relevant Additional Terms that you agreed to when registering for your User account.

  • Usage of Website. Voono gathers and processes some Data to comprehend how Users engage with the Services and enhance User experience. This Data consists of various browsing information obtained from Cookies or technical mobile identifiers (refer to the Cookie Policy), some of which may comprise Personal Data.

  • The legal basis for this processing depends on your location and the applicable law. In countries where the use of cookies is contingent on the Users' prior consent, Voono processes this Data based on your consent. In other countries, Voono processes this Data on the grounds of (i) its legitimate interest, including understanding how its Services are utilised by Users and improving the Services if needed, or (ii) your consent, depending on the purpose of the cookie.

  • Access to and Use of the Services. Voono collects and processes Personal Data to grant you access to and use the various aspects of the Services, including facilitating the acquisition of a Collectible, engaging in the Game, or participating in our Referral Programs.

  • To buy a Collectible on the Primary Market and/or purchase, transfer, withdraw, and/or exchange a Collectible via the Marketplace, Voono collects your username, phone number, or payment identifier and has access to a portion of your credit card number (e.g., the last four digits of the credit card that we can access through payment service providers but do not directly collect or store).

  • To facilitate participation in a Tournament, send prizes to the winners, publish leaderboards, and more, Voono processes your username and the prize(s) you have won (where applicable). Voono may publish your username and the prize(s) you have won on its Website, as part of the leaderboard presenting the results of the tournaments.

  • To allow participation in our Referral program, Voono collects and processes your email address, username and the referral code specific to your user profile.

  • The legal basis of this processing is contractual. We require this data to execute the Terms and Conditions, and any other applicable Additional Terms, that you agreed to when signing up for your User account.

  • Terms Compliance; Website and Account Security. Voono collects certain device and browser information (user agent), browsing data, including IP address (from which information on your country/state of location can be inferred), account information (including your email address and phone number), and transaction details, to ensure the security of the Services and your User account, and to detect, prevent, investigate, and/or trace any attempt to violate our Terms and Conditions or any other Applicable Terms, such as by malicious hacking. In the course of an investigation, Voono may take additional security measures, including but not limited to requesting additional supporting documents and/or information, or suspending or cancelling the relevant transaction in the event the transaction cannot be verified. Where payment fraud has been investigated and confirmed, the relevant Data and other related information will be stored in Voono’s monitoring system and used for future verifications.

  • The legal basis of this processing is Voono’s legitimate interest. Voono has a legitimate interest in detecting, preventing, and investigating fraud to ensure a fair game for all users and to protect its Services and Users against potential credit card frauds.

  • User Requests and Communication. Voono collects and processes Personal Data, such as your username, contact details, and the content of your message (to the extent such content is considered Personal Data) when managing and following up on any questions and/or requests you may submit via help@voono.io.

  • The legal basis of this processing is contractual. Support is integral to the Services we provide, so we require this data to execute the Terms and Conditions, and any other applicable Additional Terms, that you agreed to when signing up for your User account.

  • Data Transfers Outside the EEA: Voono may transfer your personal data outside of the European Economic Area. When we do so, we ensure that appropriate measures are in place to protect your personal data and to comply with our obligations under applicable data protection law. This may include entering into contracts in the form approved by the European Commission, or ensuring that the company to which we transfer your personal data has agreed to abide by an approved transfer mechanism, such as the EU-US Privacy Shield.
3. Blockchain Technology

  • Utilisation of Blockchain Technology: Voono utilises blockchain technology, specifically the Polygon blockchain, for conducting various services and transactions. This technology involves a decentralised and distributed ledger that ensures a permanent, tamper-proof record of transactional data.

  • Immutable Nature of Blockchain: Due to the inherent nature of blockchain technology, Personal Data processed and logged on the Polygon blockchain in connection with your transactions on Voono will be stored immutably. This means that once the Personal Data is recorded on the blockchain, it cannot be altered or deleted, a characteristic essential for ensuring the authenticity and integrity of the transactions.

  • Data Minimisation and Blockchain: The categories of Personal Data that may be logged on the public Polygon blockchain include transactional data such as your public keys, transaction timestamps, and transaction amounts. Voono applies data minimisation principles, which means we only log the minimum necessary data on the blockchain. Sensitive information is never recorded on the blockchain and should always remain private.

  • Protection of Personal Data: Voono has implemented several robust measures to protect your Personal Data in connection with the use of blockchain technology. These measures include advanced encryption techniques and stringent access controls.

  • User Responsibilities: You also play a crucial role in protecting your Personal Data. We encourage you to not share sensitive information and always ensure the security of your private information. Remember, while your identity may not be readily discernible from the transaction data on the blockchain, any transaction data is publicly visible to anyone with knowledge of the blockchain.

  • Legal Basis for Processing: The legal basis for this processing is Voono’s legitimate interest in maintaining the integrity of its blockchain-based services, ensuring the security of User transactions, and complying with legal requirements.

  • Compliance with Data Protection Laws: Voono's approach to blockchain technology adheres to the principles of transparency, purpose limitation, and data minimisation in accordance with the UK’s Data Protection Act 2018 and the GDPR. However, the use of blockchain technology for processing personal data is a rapidly evolving area of law. We recommend seeking specialist legal advice to ensure full compliance with all relevant legal requirements.
4. Data Retention

  • Account Details. Voono will store your Personal Data until your account is closed. However, if required or permitted by applicable law, and if Voono needs to retain specific Personal Data beyond the date of account closure, the longest applicable retention period will apply, in accordance with the relevant statutory limitation periods. This duration will not surpass the period that the Company must retain the Data.

  • Website Usage. Personal Data processed by or for Voono for analytics or other research purposes will not be retained by Voono after the completion of such studies and the production of relevant reports, outputs, and/or insights.

  • Service Access. Personal Data processed for utilising the Services will be retained for fifteen (15) months from the date of the relevant activity.

  • Blockchain Technology. Personal Data processed and logged on a blockchain in connection with your transactions on Voono will be stored immutably. Refer to the "Blockchain technology" section above for further information on the categories of information logged on the public Polygon blockchain and the measures Voono has implemented to protect your Personal Data.

  • Terms Compliance. Website and Account Security. Personal Data processed for fraud prevention will be retained for three (3) years after being included on an alert list. Personal Data processed for security matters will be kept for five (5) years from the last account login or suspicious activity.These retention periods are subject to regular review and may be shortened or extended as required by law, regulatory obligations, or as necessary for the proper administration of our Services.

  • User Inquiries and Communication. For managing your questions and/or requests, Voono will retain your Personal Data for a maximum of three (3) years after your last interaction with us.
Despite the above, Voono may store some Personal Data for longer durations due to its legitimate interests and applicable legal obligations. Upon the expiration of the relevant retention period, Voono will delete your Personal Data or implement adapted measures to ensure that you can no longer be identified. If Voono determines that retaining your Personal Data in its active database is unnecessary, it will archive the pertinent Data. For all active and archived Data, Voono will ensure access to the relevant Data is restricted to a limited number of individuals with a genuine need for access.
5. Processors and Data Transfers

Voono may utilise Third-Party Service providers and other third parties ("Processors") to facilitate, maintain, improve, analyse, and secure the Website, App, and Services. Processors may access Personal Data exclusively for the purpose of performing the processing activity assigned to the respective Processor by Voono. Voono ensures that the service providers offer sufficient guarantees for executing the processing activity and comply with the applicable laws and regulations.
Personal Data may be processed outside the European Economic Area ("EEA"). When Data is transferred outside of the EEA, Voono will take all necessary precautions and, alternatively or cumulatively: (i) ensure that the European Commission has made an adequacy decision regarding the destination country, (ii) sign model contractual clauses adopted by the European Commission or the supervisory authority with the recipient, (iii) ensure that the recipient adhered to an approved code of conduct or certification mechanism, etc.
6. Data Sharing

The Company shares your Personal Data with Third-Party Service providers and suppliers to help the Company achieve the purposes outlined in this Policy.
Third-Party Services

  • Some content or features of the Website and/or App are provided by Third-Party Service providers. To facilitate your access to such content and/or features, Voono may share some of your Personal Data with Third-Party Services and suppliers. The Third-Party Service may request additional Data from you. Regardless of whether they are directly integrated into the Website and/or App, these Third-Party Services collect and process any Data they receive according to their respective privacy policy, under that provider's sole responsibility.

  • Please note that the contractual agreements between Voono and our Third-Party Service Providers (such as payment services providers or marketing partners) specify that both Voono and the Third-Party Service Provider will act as an "independent controller" as defined by the GDPR (or "Business" as defined by the CCPA) and must comply with all applicable data protection laws and regulations. Please consult the relevant privacy policy of the corresponding Third-Party Service for more information.
Partner Sports Leagues, Teams, and Clubs

  • Our partner sports leagues, teams, and clubs ("Partner(s)") contribute to Voono's greatness. Voono may share your email address and username with these trusted Partners for the relevant Partner's own direct marketing and promotional purposes. During User account registration, you can choose whether or not you consent to us sharing such Data with our Partners. This choice is completely yours - if you do not consent, we will not share the Data.
If you do consent, please note that the contractual arrangements between Voono and its Partners specify that both Voono and each Partner will act as an "independent controller" as defined by the GDPR (or "Business" as defined by CCPA) and must comply with all applicable data protection laws and regulations. Please consult the relevant privacy policy of the corresponding Partner for more information.
Judicial and Governmental Authorities

  • Where required by law or a valid court order, and to the extent legally permitted, Voono may share your Personal Data with competent courts and/or other governmental and/or public authorities requesting access to your Personal Data.

  • We take sharing your Data seriously. Whenever we share your Personal Data with any of the recipients mentioned above, we do so on a strictly need-to-know basis and only as necessary for fulfilling identified processing purposes
7. Data Breach Notification

  • Security Measures and Compliance: Voono is committed to the security of your personal data and has in place physical, administrative and technical measures designed to prevent unauthorised access to that information. Our Information Security policies and procedures are closely aligned with widely accepted international standards and are reviewed regularly and updated as necessary to meet our business needs, changes in technology, and regulatory requirements.

  • Breach Procedures: Despite our robust and layered security, in the unlikely event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data, we will assess the risk to your rights and freedoms and if appropriate, report this breach to the Information Commissioner's Office (ICO) within 72 hours of becoming aware of it, in accordance with the General Data Protection Regulation (GDPR).

  • User Notification: If the breach is likely to result in a high risk to your rights and freedoms, we will also inform you without undue delay. This notification will include information on the nature of the personal data breach, the likely consequences of the personal data breach, the measures we have taken or propose to take to address the personal data breach, and our recommendations for you to mitigate any potential adverse effects.

  • Communication Methods: Notifications may be sent via email, mail, phone calls, or text messages, as allowed by law.
8. Use by Children

The Website, App, and Services are designed for use by individuals who are eighteen (18) years old or older. As per the Terms and Conditions, the Website, App, and Services are not available to Users under 18 years of age.
9. Your Rights

Most applicable data privacy laws (including the European Union's GDPR, and some American states' laws, such as the CCPA) grant individuals rights concerning their Data and how that Data is processed. The following section aims to inform you of your rights concerning your Personal Data. Please note that all requests under this section will be processed according to applicable European laws (mainly GDPR) regardless of your location or country of residence, but our responses may be adapted to comply with local law requirements.
You have the right to access your Personal Data, correct it, move it, delete it, and the right to restrict how your Data is processed. You also have the right to specify instructions defining how Personal Data should be managed after your death.

  • To exercise your rights or make an inquiry regarding data privacy at Voono, you should submit a request accompanied by proof of identity by email at help@voono.com.

  • Voono will try to respond to your request or inquiry as soon as possible, and at the latest within one (1) month of receipt of the request. For complex requests, we reserve the right to extend this period to three (3) months.
Deletion of User account

  • If you intend to request the deletion of your Personal Information, you can use the method described above or simply request the deletion of your User account via the settings of your User account as described in Voono's terms and conditions.

  • The deletion of your account will result in the irreversible deletion of the Personal Data associated with the account. To respect your rights without altering the history and traceability of each Collectible you owned, the username associated with the ownership of these Collectibles will be pseudonymized and replaced by a random series of alphanumeric characters.

  • You must save any Collectibles stored in the Wallet to an external wallet before any deletion request. Any Collectibles stored on Voono that have not been transferred out of your account at the date of deletion will be permanently irretrievable. Voono will not be responsible for the permanent loss of any Collectibles not saved before a deletion request.
Protecting your Personal Data and complying with the applicable data protection legal framework are two of Voono's top priorities, and we need your help to be successful. By agreeing to this Policy, you agree to keep your Data on Voono up-to-date and provide only accurate and current Personal Data. Additionally, if you send us any information that would allow us to identify, directly or indirectly, any other individuals, you represent and warrant that, before sharing this information, such other natural persons have been provided with this Policy and, to the extent applicable, have consented to the processing of their Data.
10. Cookies

Our Services utilise cookies and similar technologies to distinguish you from other users and to gather certain personal data about you. A cookie is a small file stored on your device, containing information transferred to your device's storage.
By using our Services, you're consenting to our use of cookies as described in this clause. You have the right to withdraw this consent or modify your cookie preferences at any time.
We utilise different types of cookies:
  • Strictly Necessary Cookies: Essential for the operation of our Services, enabling features like secure login, shopping cart usage, and e-billing services.

  • Analytical or Performance Cookies: Help us understand visitor numbers and behaviour, aiding in website optimization.

  • Functionality Cookies: Enable personalised content by recognizing you upon return visits.

  • Targeting Cookies: Track your activity to provide relevant content and advertising. Information may be shared with third parties for this purpose.

  • Third Party Cookies: Provided by third parties, such as Google Analytics or social media platforms. The data collected by these cookies is managed according to the third party's privacy policy.
The duration of cookie storage varies. Session cookies are temporary and expire when you exit our website or close your browser. Persistent cookies remain for a predetermined period, allowing our Services to recognize your device on return visits.
You can manage cookies through your browser settings, including refusing or being alerted about new cookies. Disabling cookies may affect our Services' functionality.
This Cookie Use Clause may be updated periodically due to legal, technical, or business developments. You'll be informed appropriately of any significant changes.
11. Security

Voono has implemented and maintains measures to protect the confidentiality, security, and integrity of your User account and Personal Data against unauthorised access and disclosure, modification, alteration, damage, accidental loss, or accidental or illicit destruction, as well as against any other form of unauthorised processing or disclosure.
We recommend you observe security best practices, including storing your account information securely and not sharing account information. Please note that our backup services will not make a backup of your data to your personal, local storage or drive; we recommend you use a secondary backup source and/or other best practices for the preservation of data. Additionally, we recommend you use a password manager for any and all password-protected features of your User account and your User account itself.
12. Updates to this Privacy Policy

Voono reserves the right to change this Policy as necessary, as the Service evolves or as required by applicable laws. Any material Policy changes will be communicated to you. When using the Services, you are deemed to have accepted the terms of the Policy, as published on our Website.
13. Jurisdiction and Applicable Law

Voono reserves the right to change this Policy as necessary, as the Service evolves or as required by applicable laws. Any material Policy changes will be communicated to you. When using the Services, you are deemed to have accepted the terms of the Policy, as published on our Website.
Subject to applicable law, you agree that the courts of England and Wales will have exclusive jurisdiction over any dispute arising out of or relating to this Policy. However, if you are a consumer and resident of any European Union country, you will benefit from mandatory provisions of, and legal rights available to you under, the laws of that country. Nothing in this Policy affects your rights as a consumer to rely on these local law mandatory provisions and legal rights.
Subject to applicable law, you agree that the courts of England and Wales will have exclusive jurisdiction over any dispute arising out of or relating to this Policy. However, if you are a consumer and a resident of another country in the European Union, you may also have the right to bring proceedings in your resident country.