Privacy Policy

Last updated on July 26th, 2018 (hereinafter referred to as the “website” or “site”) is a free portal about Clash&GO ICO project provided to the public by Topgames Limited, company, incorporated in the jurisdiction of the British Virgin Islands (hereinafter referred to as “we”, or “us”). As data controller, we appreciate your visit and interest in our company, products, and services. We value the importance of protecting your privacy and personal data. To ensure transparency and security, our privacy policy as set forth below will inform you about the nature, scope, and purpose of the personal data processed by us. This privacy policy also explains how personal information (personal identifiable information, personal data) is collected, used and disclosed by us while using the website, or any services or products made available through this site (collectively, the “services”), or when you otherwise interact with us.

We reserve the right to update this privacy policy at any time without prior notice. We will process data in accordance to the privacy policy that you have consented to at the time of your consent. Upon a change in policy, we will alert you with a conspicuous website banner notice; your continued use of the website and/or its services will constitute your consent to the updated policy. Use the “Last Updated” date in this policy to determine when it was last changed.

Please note that if your company has a separate agreement with us, it will govern the processing of all information and data collected by us in connection with the services, including some data collected through our websites. Such agreement takes precedence over any conflicting provision in this privacy policy.


What do we mean under personal identifiable information or personal data?

Personal data or personal identifiable information means any information relating to an identified or identifiable natural person. The definition of personal data now encompasses not only natural person’s explicit identifiers like name or address, but also any online identifiers together with other personal data.


What personal information do we collect from the people that visit our website?

We collect, process, or use the following categories of personal data, if you provide it to us:

  • Your email address when registering on our site,
  • Your name, address, citizenship, date of birth, photo, job title, as well as other information required for “know your customer” and “anti-money laundering” checks where applicable,
  • Number of your crypto wallet,
  • Other data that you have provided while contacting us, especially using the contact, download, or signup forms on our website,
  • Data that you have sent to us through an online survey or support ticket.

For marketing purposes and to improve our websites and services, we also collect data sent by your web browser, e.g., information about your browser, your IP address, and your operating system.


Children’s data

We do not provide any services to children. We may process personal data in relation to children only provided that our customer mistakenly submits this information without our notice. For the purposes of this privacy policy, “children” are individuals who are under the age of eighteen (18). We encourage you to talk to your children about safe and responsible use of their and your personal information while surfing Internet and visiting such websites like ours.


When do we collect information?

We collect information from you when you surf the website, register on our site, place an order, subscribe to a newsletter, fill out a form or enter information on our website, respond to a survey or marketing communication, or use certain other site features.


How and for what purposes do we use your information?

We collect and process your personal data in order to:

  • Provide you with the services that you seek from our website and customer support per your request;
  • Process transactions and send notices about your transactions, including tokens distribution;
  • Improve our websites and services;
  • Resolve disputes, collect fees, and troubleshoot problems;
  • Conditions or other legal documents;
  • Prevent potentially prohibited or illegal activities, and enforce Public Offer Agreement, or our Terms and Conditions or other legal documents;
  • Ensure the security of our website and our services;
  • Better market relevant content generally, using anonymous or pseudonymized personal data;
  • And, if you have additionally consented to it, market to you specifically, such as through email remarketing and web retargeting.

Beyond these purposes, we process your data only if you have granted express consent for its stated purposes.


What is the legal basis for processing your personal information?

As mentioned earlier we are committed to protecting your privacy and handling your data in an open and transparent manner and as such we process your personal data for one or more of the following reasons:

  • For the performance of a contract. We process personal data in order to offer services based on contracts with our customers but also to be able to complete the procedure so as to enter into a contract with prospective customers. The contract terms and conditions provide more details of the relevant purposes.
  • For compliance with a legal obligation. There are a number of legal obligations emanating from the relevant laws to which we are subject as well as statutory requirements (i.e. KYC and AML check procedures). Such obligations and requirements impose on us necessary personal data processing activities for compliance with, for example, court orders, tax law or other reporting obligations.
  • For the purposes of safeguarding legitimate interests. We process personal data so as to safeguard the legitimate interests pursued by us or by a third party. A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. Examples of such processing activities include: initiating legal claims and preparing our defense in litigation procedures: measures to manage business and for further developing our products and services.
  • You have provided your consent. Provided that you have given us your specific consent for processing (other than for the reasons set out hereinabove) then the lawfulness of such processing is based on that consent. You have the right to revoke consent at any time. However, any processing of personal data prior to the receipt of your revocation will not be affected.


Third-party disclosure

We do not sell or rent your personal information to third-parties. We do not share your personal information, except as provided in this privacy policy.

We use third-party data processors to process personal data on our behalf. Such service providers support our website and services, especially relating to hosting and operating the websites, marketing, analytics, improving the website, and sending email newsletters. These processors may be located outside the European Union. Such service providers and suppliers enter into contracts with us by which they observe confidentiality and data protection requirements according to the data protection law and the GDPR or other personal data protection rules which may be applicable.

Our websites may also include social media features (e.g., share or like buttons). Such features are provided by third-party social media platforms such as LinkedIn, Twitter, or Facebook and others. Where data is collected this way, its processing is governed by the privacy policy of the respective social media platforms.

We may also share your personal information with other entities of our corporate group. Such disclosure is regulated by our internal corporate privacy policies.

It must be noted that we may disclose information about you for any of the reasons set out hereinabove, or if we are legally required to do so, or if we are authorized under our contractual and statutory obligations, or if you have given your consent to do so. All data processors appointed by us to process customer data on our behalf are bound by contract to comply with the GDPR provisions or other personal data protection rules which may be applicable.

Under the circumstances referred to above, recipients of personal data may be, for example: crypto exchanges where our tokens are listed; supervisory and other regulatory and public authorities; external consultants, financial and business advisors; auditors and accountants; marketing operators; card payment processing companies; file storage companies, archiving and/or records management companies, cloud storage companies; companies who assist us with the effective provision of our services to you by offering technological expertise, solutions and support; website and advertising agencies.

For Japanese residents only: your personal and other data in the scope of email address, ID of your wallet and your IP address which indicates that you are from Japan, will be available for our partner in Japanese market - CoinJapan, CO., LTD and its subcontractors engaging participants in our project. These data will be available only for reference with the purpose to verify the correctness of remuneration accrual for CoinJapan, CO., LTD and its subcontractors.

Our content may link to third party websites to provide relevant references. We are not responsible for such external websites, which may contain separate privacy policies and data processing disclosures. We may disclose your personal information if required by law, regulation, or other legal subpoena or warrant. We may also disclose your personal information to a regulatory or law enforcement agency if we believe it to be necessary to protect the rights, property, or personal safety of our company, its customers or any third party.


Email communications

If you have given us your email for purposes of communication or promotion, we will use your data to contact you or send promotional emails relating to your interests. You may revoke your consent to being contacted by email for promotional purposes any time, by clicking on an unsubscribe link or replying directly stating your wish to unsubscribe.

Further, with your consent, we may make use of email tracking technology to obtain data on if you open an email or if you click on links in an email. This data will be used only in automated ways to help improve future marketing messaging and/or to prioritize follow ups based on perceived communications relevance. Without your consent, we will not make use of personal data unique to you, such as your IP address, your device and browser information, or the time and number of times you open an email or click on a link.


Correct/update/remove​ ​information

You have the right to access your personal information and to require the correction, updating or deletion of incorrect or/and inaccurate data by contacting us via [email protected] or [email protected]. Nevertheless, this request must comply with Terms and Conditions and other legal obligations that may arise. Upon the accepted request, we will provide you with the personal information that we collect and store about you and general disclosure of your personal information.


Retain information

As required by applicable laws and as needed to provide services to our users, we may hold your personal information. This requirement is conditioned by the need of complying with legal obligations and resolving possible disputes. We may retain your personal information so long as your account is active.
We may keep your data for longer if we cannot delete it for legal, regulatory or technical reasons.


How do we protect your information?

Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.

We use regular malwares canning. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. We provide training to our employees on data protection best practices and require them to enter into a confidentiality agreement. In addition, all personal information you supply is encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures when a user places an order, enters, submits, or accesses their information to maintain the safety of your personal information. However, while we use all reasonable efforts to protect your personal information, we cannot guarantee the absolute security of your data submitted through our websites.


Do we use “cookies”?

Yes. When you visit our websites, our system automatically collects information about your visit, such as your browser type, your IP address, and the referring website.

This collection may be done in conjunction with our vendors and partners (see data processors list below). We may receive from them general demographic or usage data of our site visitors. We do not use automatically collected information to identify you personally without collecting additional consent.
Such information is typically collected using web cookies, web or email pixels (also known as beacons), embedded hyperlinks, and similar tools. Popular browsers can generally be set to disable or delete individual cookies. See below for the types of cookies we use and their respective purposes.

  • Required Cookies: enable the navigation and basic functionality of the website, e.g., access to protected areas of the websites.
  • Functional Cookies: allow us to analyze your website usage and your selections on the website (e.g. your login name, language, or region), so we can save these settings and offer you a more personalized experience.
  • Advertising Cookies: allow us to better assess the effectiveness of our content marketing and advertising efforts. These cookies are provided by our third-party partners to analyze and track site visit and signups stemming from advertising. We do not share your personal information (such as name or email) to third-party providers outside of site visit data collected directly by such Advertising Cookies, though your site visit data may be linked with other personal information collected elsewhere by such third-party providers. Such external data processing is governed by the privacy policies of these third-party providers.

See below for descriptions about the cookies used on our websites and how you can opt out from them.


Required Cookies

Our website stores various cookies that are required for the navigation and usage of the websites.
Opt-out: You can configure your browser to disable these Required Cookies. This may reduce site functionality.


Google Analytics (Functional Cookies)

Our website uses Google Analytics, a web analysis service of Google, Inc. (“Google”). Learn more from their Terms of Service and Privacy Policy.
Opt-out: Download the browser plugin “Google Analytics Opt-out Browser Add-on” here.


Google AdWords (Advertising Cookies)

Our website uses Google AdWords Conversion Tracking cookie to measure and optimize the performance and user experience related to our ads in Google Search or selected Google Display Network sites. Learn more about Google’s privacy policy here.
Opt-out: Visiting Google’s Ads Settings.


We use cookies to:

  • Help remember and process your choices in your account.
  • Understand and save user's preferences for future visits.
  • Keep track of advertisements.
  • Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browsers differ from each other a little, look at your browser's help menu to learn the correct way to modify your cookies. If you turn cookies off, some of the features that make your site experience more efficient may not function properly.


How does our site handle Do Not Track signals?

We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.


Contacting Us

If there are any questions regarding this privacy policy or processing of your personal data, you may contact us using mail address: [email protected].