PRIVACY POLICY

Earniverse, Inc. a C-corp registered in Delaware – USA with file number 10122844 and its registered office at 254 Chapman Rd, Office 86 – Suite 101B, Newark, DE 19702 | USA.

Earniverse (“EIV,” “we”, “us”, or “our”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect, use, and share in connection with the Earniverse websites (company website, support website, documentation website, news website and any others), marketplace application, and other software provided on or in connection with our services, as described in our Terms of Service (collectively, the “Service”). “collectible” in this Privacy Policy means a non-fungible token or similar digital item implemented on a blockchain (such as the Avalanche blockchain), which uses smart contracts to link to or otherwise be associated with certain content or data.

I- Types of Data We Collect

“Personal Data” means data that allows someone to identify you individually, including, for example, your name, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing. “Anonymous Data” means data, including aggregated and de-identified data, that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data as described below.

1. Information provided by the users.
   1. When you use our Service, update your account profile, or contact us, we may collect Personal Data from you, such as email address, first and last name, username, and other information you provide. We also collect your blockchain address and related informations regarding your wallet, which may become associated with Personal Data when you use our Service.
   2. Our Service lets you store preferences like how your content is displayed, notification settings, and favorites. We may associate these choices with your ID, browser, or mobile device.
   3. If you provide us with feedback or contact us, we will collect your name and contact information, as well as any other content included in the message.
   4. We may also collect Personal Data at other points in our Service where you voluntarily provide it or where we state that Personal Data is being collected.
2. Information Collected via Technology. As you navigate through and interact with our Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
   1. Information Collected by Our Servers. To provide our Service and make it more useful to you, we (or a third party service provider) collect information from you, including, but not limited to, your browser type, operating system, Internet Protocol (“IP”) address, mobile device ID, blockchain address, wallet type, and date/time stamps.
   2. Log Files. As is true of most websites and applications, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamps, and clickstream data. We use this information to analyze trends, administer the Service, track users’ movements around the Service, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Service, it will recognize you and the information can be used to personalize your experience.
   3. Cookies. Like many online services, we use cookies to collect information. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to analyze how users interact with our Service, make improvements to our product quality, and provide users with a more personalized experience.
   4. Pixel Tag. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags allow us to analyze how users find our Service, make the Service more useful to you, and tailor your experience with us to meet your particular interests and needs.
   5. Email Tracking. With your consent, our emails include a small invisible image and personalized links. They tell us when you open an email and which links you click, along with basic technical data (date, email app, approximate device and IP address). We use this to personalize the emails we send you and offer you content that matches your interests. Legal basis: your consent, which you can withdraw at any time from your account settings or with the “Manage” link at the bottom of each email; withdrawing does not stop you from receiving your emails. Without your consent, we only keep anonymous overall statistics and check whether our emails are still being read, so we can send fewer emails to inactive addresses. Email tracking stays off for accounts under 18. Our emails are sent by Brevo (Sendinblue SAS, France), which processes this data on our behalf in the European Union. Tracking data is kept for 12 months, then deleted.
   6. How We Respond to Do Not Track Signals. Our systems do not currently recognize “do not track” signals or other mechanisms that might enable Users to opt out of tracking on our site.
   7. Analytics Services. In addition to the tracking technologies we place like Cookies and Pixel Tags, other companies may set their own cookies or similar tools when you visit our Service. This includes third-party analytics services (“Analytics Services”) that we engage to help analyze how users use the Service. The information generated by the Cookies or other technologies about your use of our Service (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity, which we may receive on an individual or aggregate basis. We use the information we get from Analytics Services to improve our Service. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ terms of use and privacy policy. By using our Service, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above.
3. Information Collected from Third-Party Companies. We may receive Personal and/or Anonymous Data about you from companies that offer their products and/or services for use in conjunction with our Service or whose products and/or services may be linked from our Service. For example, third-party wallet providers provide us with your blockchain address and certain other information you choose to share with those wallets providers. We may add this to the data we have already collected from or about you through our Service.
4. Public Information Observed from Blockchains. We collect data from activity that is publicly visible and/or accessible on blockchains. This may include blockchain addresses and information regarding purchases, sales, or transfers of collectibles, which may then be associated with other data you have provided to us.

II- Use of Your Personal Data

1. We process your Personal Data to run our business, provide the Service, personalize your experience on the Service, and improve the Service. We can use your Personal Data to:
   1. facilitate the creation of and secure your account;
   2. identify you as a user in our system;
   3. provide you with our Service, including, but not limited to, helping you view, explore, and create collectibles using our tools and, at your own discretion, connect directly with others to purchase, sell, or transfer collectibles on public blockchains;
   4. improve the administration of our Service and quality of experience when you interact with our Service, including, but not limited to, by analyzing how you and other users find and interact with the Service;
   5. provide customer support and respond to your requests and inquiries;
   6. investigate and address conduct that may violate our Terms of Service;
   7. detect, prevent, and address fraud, violations of our terms or policies, and/or other harmful or unlawful activity;
   8. display your username next to the collectibles currently or previously accessible in your third-party wallet, and next to collectibles on which you have interacted;
   9. send you a welcome email to verify ownership of the email address provided when your account was created;
   10. send you administrative notifications, such as security, support, and maintenance advisories;
   11. send you notifications related to actions on the Service, including notifications of offers on your collectibles;
   12. send you newsletters, promotional materials, and other notices related to our Services or third parties’ goods and services;
   13. respond to your inquiries related to employment opportunities or other requests;
   14. comply with applicable laws, cooperate with investigations by law enforcement or other authorities of suspected violations of law, and/or to pursue or defend against legal threats and/or claims; and
   15. act in any other way we may describe when you provide the Personal Data.
2. We may create Anonymous Data records from Personal Data. We use this Anonymous Data to analyze request and usage patterns so that we may improve our Services and enhance Service navigation. We reserve the right to use Anonymous Data for any purpose and to disclose Anonymous Data to third parties without restriction.

III- Disclosure of Your Personal Data

1. We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.
2. Third Party Service Providers. We may share your Personal Data with third party service providers to: provide technical infrastructure services; conduct quality assurance testing; analyze how our Service is used; prevent, detect, and respond to unauthorized activities; provide technical and customer support; and/or to provide other support to us and to the Service.
3. Affiliates. We may share some or all of your Personal Data with any subsidiaries, joint ventures, or other companies under our common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.
4. Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
5. Legal Rights. Regardless of any choices you make regarding your Personal Data (as described below), Earniverse may disclose Personal Data if it believes in good faith that such disclosure is necessary: (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas, warrants, or other legal process served on Earniverse; (c) to protect or defend the rights or property of Earniverse or users of the Service; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Service.
6. Other Disclosures. We may also disclose your Personal Data: to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide it; or with your consent.

III.2- Risk Disclosure 

• By accessing or using the Company Services, you expressly acknowledge and assume the following risks:
• Risk of loss of assets or loss in value for Assets.
• Many factors may affect the value of Assets, which may result in the permanent, partial or total loss any Asset. The Company is not obliged to guarantee the Assets or value of assets managed by the Company.
• The regulatory regime governing Digital Assets and the regulatory framework relating to Digital Assets remains unsettled, and any laws, regulations, or guidelines may be significantly revised and amended which shall materially and adversely affect the value of Digital Assets and your services on the Company Platform as follows:
• (a) Regulations of the use, transfer, and exchange of Digital Assets in various jurisdictions are currently undeveloped or underdeveloped and likely to evolve rapidly. One or more countries shall take regulatory actions in the future that severely restricted, which may directly or indirectly affect or restrict the Company Services provided to Users;
• (b) To the extent that the Company may be required to obtain licenses, permits, and/or approvals in any jurisdictions to offer the Company Services, but are unable to obtain such Regulatory Approvals or if such Regulatory Approvals are not renewed or revoked for any reasons, the Users in such jurisdictions shall be unable to access or use the Company Services;
• (c) It is difficult to predict how or whether governments or regulatory authorities may implement any changes to laws and regulations affecting the use, transfer, and exchange of Digital Assets. In the case where the Company may be requested or forced to suspend or discontinue or to change the operation of the Company Services in any jurisdictions required by laws and the authorities, your Account with the Company may be frozen for an indefinite period of time until the matter is resolved. You shall be responsible for determining whether the use of the Company Services is legal in your jurisdiction, and you shall not access or use the Company Services if they are illegal in your jurisdiction. If you are uncertain on the legal status of Digital Assets in your jurisdiction, please seek independent advice from your legal advisor.
• Technical and System Failure affected the obligations stipulated in these Terms means that the Company may experience system failures, unplanned interruptions in its network or services, hardware or software defects, security breaches, services unavailability or other causes that could adversely affect the Company’s services, which includes the Company’s website.  The Company is unable to anticipate when there would be the occurrence of hacks, cyber-attacks, mining attacks, including but not limited to double-spend attacks, majority mining power attacks and selfish-mining attacks, distributed denials of services or errors, vulnerabilities or defects in the Company, Token, Users’ accounts, Users’ wallets or any technology, including but not limited to smart contract technology. The Company is unable to detect these hacks as mentioned earlier, mining attacks, cyber-attacks, distributed denials of services errors vulnerabilities or defects in a timely manner and does not have sufficient resources to efficiently cope with multiple services incidents happening simultaneously or in rapid succession.  In addition, the Company’s network or Services, including the Company Platform, could be disrupted by numerous events, including natural disasters, equipment breakdown, network connectivity downtime, power losses, or even intentional disruptions of its services, such as disruptions caused by software viruses or attacks by unauthorized users, some of which are beyond the Company’s control. Although the Company has taken steps against malicious attacks on its appliances or its infrastructure, which are critical for the maintenance of the Company Platform and its services, there can be no assurance that cyber-attacks, such as distributed denials of service, shall not be attempted in the future, and that the Company’s enhanced security measures shall be effective. Any significant breach of the Company’s security measures or other disruptions resulting in a compromise of the usability, stability and security of the Company’s network or services, including the Company Platform, may adversely affect the Tokens.
• The Company shall have no liability for any delay, error, interruption or failure to perform any obligation under these Terms where the delay or failure is directly or indirectly resulting from any causes beyond the Company’s control, including but not limited to:
  • (a) Acts of God, nature, court of government;
  • (b) Failure or interruption in public or private telecommunication networks, communication channels or information system;
  • (c) Acts or omission of acts of a party for whom we are not responsible;
  • (d) Delay, failure or interruption in, or unavailability of, third-party services; or
  • (e) Strikes, lockouts, labour disputes, wars, terrorist acts and riots.
• You understand and agree that you use the Company services at your own risk.   This clause is not exhaustive and does not disclose all the risks or potential risks that may be associated with Assets, Assets management and the use of the Company’s various services. You are strongly recommended to carefully consider whether such use is suitable for you in light of your circumstances and financial positions.

IV- Third-Party Websites

Our Service may contain links to third-party websites. When you click on a link to any other website or location, you will leave our Service and go to another site, and another entity may collect Personal Data from you. We have no control over, do not review, and cannot be responsible for these third-party websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these third-party websites or their content, or to any collection of your Personal Data after you click on links to such third-party websites. We encourage you to read the privacy policies of every website you visit. Any links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.

V- Third-Party Wallets

To use our Service, you must use a third-party wallet which allows you to engage in transactions on public blockchains. Your interactions with any third-party wallet provider are governed by the applicable terms of service and privacy policy of that third party.

1. Your Choices Regarding Information. You have several choices regarding the use of information on our Services:
   1. Email Communications. We may periodically send you newsletters and/or emails that directly promote the use of our Service or third parties’ goods and services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving these communications from us by following the unsubscribe instructions provided in the email you receive or through the Notifications preferences in your Settings page. Despite these preferences, we may send you occasional transactional service-related informational communications.
   2. If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service.

VI- Data Access and Control

You can view, access, edit, or delete your Personal Data for certain aspects of the Service via your Settings page. You may also have certain additional rights:

1. If you are a user in the European Economic Area or United Kingdom, you have certain rights under the respective European and UK General Data Protection Regulations (“GDPR”). These include the right to (i) request access and obtain a copy of your personal data; (ii) request rectification or erasure; (iii) object to or restrict the processing of your personal data; and (iv) request portability of your personal data. Additionally, if we have collected and processed your personal data with your consent, you have the right to withdraw your consent at any time.
2. If you are a California resident, you have certain rights under the California Consumer Privacy Act (“CCPA”). These include the right to (i) request access to, details regarding, and a copy of the personal information we have collected about you and/or shared with third parties; (ii) request deletion of the personal information that we have collected about you; and (iii) the right to opt-out of sale of your personal information. As the terms are defined under the CCPA, we do not “sell” your “personal information.”
3. If you wish to exercise your rights under the GDPR, CCPA, or other applicable data protection or privacy laws, please contact us using the details in Section XII, specify your request, and reference the applicable law. We may ask you to verify your identity and ask for more information about your request. We will consider and act upon any above request in accordance with applicable law. We will not discriminate against you for exercising any of these rights.
4. Notwithstanding the above, we cannot edit or delete any information that is stored on a blockchain, for example the Ethereum blockchain, as we do not have custody or control over any blockchains. The information stored on the blockchain may include purchases, sales, and transfers related to your blockchain address and collectibles held at that address.

VII- Data Retention

We may retain your Personal Data as long as you continue to use the Service, have an account with us, or for as long as is necessary to fulfill the purposes outlined in this Privacy Policy. We may continue to retain your Personal Data even after you deactivate your account and/or cease to use the Service if such retention is reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our Terms or other agreements, and/or protect our legitimate interests. Where your Personal Data is no longer required for these purposes, we will delete it. For children under 13, the periods that apply are set out in the Children’s Data Retention Policy in Section IX.2.

VIII- Data Protection

We care about the security of your information and use physical, administrative, and technological safeguards to preserve the integrity and security of information collected through our Service. However, no security system is impenetrable and we cannot guarantee the security of our systems. In the event that any information under our custody and control is compromised as a result of a breach of security, we will take steps to investigate and remediate the situation and, in accordance with applicable laws and regulations, notify those individuals whose information may have been compromised.

1. You are responsible for the security of your digital wallet, and we urge you to take steps to ensure it is and remains secure. If you discover an issue related to your wallet, please contact your wallet provider.

IX- Minors

We do not knowingly allow a child under 13 to use Earniverse without the approval of a parent or legal guardian. Section IX.1 explains how we handle the information of children under 13 and the rights of their parents. Section IX.2 states how long we keep it. Our Terms of Service require all users to be at least 18 years old. Minors who are at least 13 years old but are under 18 years old may use a parent or guardian’s Earniverse account, but only with the involvement of the account holder.

IX.1- Children under 13

This section explains how Earniverse handles the personal information of children under 13 and the rights of their parents and legal guardians (together, “parents”). It applies to the Earniverse Service, including the marketplace and the Earniverse game when it is played with an Earniverse account, and it completes the rest of this Privacy Policy. If this section and the rest of this Privacy Policy differ for a child under 13, this section applies. For a child under 13 whose account a parent has approved, this section also prevails over Article 3 of our Terms of Service, which otherwise does not allow anyone under 13 to use the Service.

1. Who we are and how to reach us

The operator that collects and keeps personal information from children through Earniverse is Earniverse, Inc., a Delaware corporation. Our postal address, telephone number, email address and contact form are listed in Section XII. Parents are welcome to contact us at any time about this section or about their child’s information.

2. How we learn that a member is under 13

Earniverse is a service for a general audience. Before a new member can use their account, we ask them to select their age range. When a member tells us they are under 13, we put the account on hold until a parent approves it, as explained below.

3. What we hold while we wait for a parent’s approval

At this stage, we only hold what the child gave us to open the account and to reach a parent:

• the username the child chose;
• the email address, if the child signed up with an email address, and the password, which we store only in scrambled (hashed) form;
• the public address of the crypto wallet, if the child signed up by connecting a crypto wallet. An account opened with an email address has no wallet at this stage;
• the language setting and the newsletter choice made on the sign up form. We send no newsletter or marketing to the child;
• the age range and the date it was declared;
• if the child joined through a referral link, the internet address used at sign up, kept to prevent referral fraud;
• the email address of the parent, once the child gives it to us.

When someone signs up with an email address, the sign up form loads Google reCAPTCHA, which receives the internet address and technical browser information.

We use this information only to ask a parent for approval, to remind the parent and the child of the closing date, to keep the account secure, and to keep proof that we handled the request as the law requires.

During the waiting period:

• the account is locked: the child can only see the approval page, give or change the parent’s email address, and sign out;
• the profile is private and the account is removed from leaderboards;
• the child’s email address is removed from our mailing list;
• we send the child no welcome, verification, marketing or other message, apart from the closing reminders described below;
• we do not measure the child’s activity, other than anonymous page counts that contain no identifier;
• the wallet cannot be used, nobody can send items to the account, and access to the game is closed.

4. How we inform the parent and how long they have to decide

When the child gives us a parent’s email address, we send the parent an email. If the parent already has an Earniverse account, we also send an in-app notification. The email explains:

• what we hold;
• what we would do with the parent’s approval;
• how to approve or decline.

The account closes 30 days after the child declared their age (the “closing date”). The email shows the exact date.

We send up to three reminders: 15 days, 5 days and 1 day before the closing date. Each goes to the parent. On the same days, we send a short message to the child’s email address saying when the account will close unless a parent approves it, and asking the child to talk to their parent. The messages to the child contain no link and no promotional content.

5. How a parent gives verifiable consent

To approve the account, the parent:

1. signs in to, or creates, an Earniverse account with the email address the child gave us, and confirms that email address;
2. verifies their identity once on that account, with an official photo identity document and a selfie that our identity check compares automatically. Only an adult can be verified;
3. opens the Guardian space while signed in, reads the consent statement and accepts it.

We record the approval in our consent register: the date, the version of the text shown, the parent’s account and the internet address used. Once the parent approves, we:

• remove the parent’s email address from the child’s record;
• unlock the account;
• only then send the child a code to confirm their own email address.

We keep the parent’s identity document and selfie for 3 years after our decision. We keep them for longer while the parent supervises at least one child account, and then until 3 years after the last supervision ends. If the parent has also sold on Earniverse, we keep them until December 31 of the fifth year after the parent’s last sale, if that date is later. Then we delete them. Images from verification attempts that we did not accept are deleted right away or within 7 days.

6. If the parent declines or does not answer

If the parent declines the request from the Guardian space, we delete the child’s account right away. If no parent approves by the closing date, we delete the account within 24 hours after that date.

We delete:

• the account, the username, the email address and the password;
• the link with any wallet;
• the parent’s email address;
• pending and past reminder emails, and notifications;
• the other data linked to the account.

If a technical link prevents us from removing the account record itself, we erase every personal detail in it and permanently disable it. We also ask our email provider to delete the child’s contact, and we check that it is gone. We then tell the parent by email that the account has been deleted.

What we keep afterwards: a log entry stating that an account was deleted, the reason and the date, with no personal information. We also keep the entries of our consent register about this account (the age range declared, the steps of the approval request and their dates; the parent’s own approval also records the parent’s internet address, never the child’s) as legal proof that we checked ages and handled the request as the law requires. We keep these entries for at least 7 years.

The child is welcome to sign up again later with a parent’s approval.

7. What we collect once a parent has approved, and how we use it

With a parent’s approval, the child can use the account. Depending on what the child does and what the parent allows, we may collect:

• Account details: username, email address (confirmed after approval), language, age range, and the first name, last name, profile picture or banner if the child adds them.
• Wallet: the public address of the wallet the parent creates for the child from the Guardian space, using the parent’s own wallet password, or of the wallet the child used to sign up.
• Activity on the marketplace: collectibles and lands held; purchases, paid with the parent’s card within the limits the parent sets, or with credits; sales and earnings, if the parent allows selling; favourites, wish lists and alerts.
• Tax details: if the parent allows selling, the tax details the parent provides and signs for the child (country of tax residence, tax number, place of birth), which the law requires us to collect and report.
• Gallery: photos and videos the child posts in the gallery. The gallery is only available if the parent has made the profile public.
• Support: messages exchanged with our support team.
• Technical and security data: the internet address and actions recorded in our security log, the date of last activity, game sessions if the child plays the Earniverse game, and notifications.

We use this information to:

• provide the account and the features the parent allowed;
• process purchases and sales;
• keep accounts secure and prevent fraud;
• meet our legal, tax and record keeping duties;
• answer support requests.

We do not use a child’s information for advertising. Advertising partners are always off for a child’s account. We do not personalise or track the emails we send to a child, and we only count anonymous page views for a child’s account.

We use internet addresses and session identifiers only to support the internal operations of Earniverse:

• keeping the service working;
• signing members in;
• protecting security and preventing fraud;
• meeting legal duties.

They are never used to contact a specific child, to build a profile of a child, or for advertising.

8. What can become public, and who we share information with

Public visibility. A child’s profile is private by default. Only a parent whose identity has been verified can make it public, through a separate approval in the Guardian space. Chatting with strangers in the game is off by default and also needs a separate approval from the parent. Without these approvals:

• other members cannot see the child’s username, profile or wallet address on Earniverse;
• the child cannot post in the public gallery.

A parent can approve the account without allowing any of these.

Blockchain. Items held or transferred with a wallet are recorded on a public blockchain. Anyone can see the wallet address and these transactions on the blockchain, even though Earniverse does not show the address of a child’s wallet to other members. When a parent creates a wallet for a child, the parent confirms that they understand this.

Service providers. We share a child’s information only with service providers that help us run Earniverse and may use it for that purpose only:

• Infomaniak Network SA (Switzerland), which hosts the servers and file storage that run Earniverse;
• Brevo (Sendinblue SAS, France), which sends our emails and receives email addresses and the content of the messages;
• Cloudflare, which delivers and protects our website and processes internet addresses;
• Google (reCAPTCHA), which receives the internet address and technical browser information when the sign up form loads, before we know a member’s age;
• Stripe, when a parent pays for the child with the parent’s card. The payment is made with the parent’s payment details and customer record. With the order, Stripe also receives an internal reference to the child’s account and the description of the items bought.

Other disclosures. We may also disclose information when the law requires it, to respond to legal process, or to protect the safety of a child or the security of our service. We do not sell or rent children’s personal information.

9. Parents’ rights and how to use them

A parent whose identity is verified and who supervises the child’s account can do the following at any time, from the Guardian space:

• Review: see all the information we hold about the child, and download a copy.
• Erase now: ask us to erase the child’s tracking and personal data right away. This covers name, pictures, gallery files, closed support conversations, activity history and internet addresses, favourites, alerts and notifications. The account stays open, privacy settings move to the most protective level, and tracking stops. Only the parent can turn it back on.
• Refuse any further collection or use: close the child’s account. The child can no longer sign in, and we erase the account 30 days after closure, except what the law requires us to keep (see Section IX.2).
• Withdraw permissions: take back any separate permission (public profile, chat with strangers, selling, spending) at any time.

Before approving, a parent can decline the request from the Guardian space. The account is then deleted right away.

Parents can also reach us through the channels listed in Section XII. Before acting on a request, we check that it comes from the child’s parent. If a parent refuses further collection or use, we may end the child’s access to the service.

10. If we learn that we hold a child’s information without approval

If we learn that we have collected personal information from a child under 13 without following these steps, we will put the account on hold and delete the information as described above. If you believe this has happened, please contact us through the channels listed in Section XII.

IX.2- Children’s Data Retention Policy

We keep a child’s personal information only as long as it is reasonably needed for the purpose for which we collected it, and never indefinitely. This policy states why we collect each type of information, why we keep it, and when we delete it.

How we delete

We remove the information from our databases so that it can no longer be retrieved in the normal course of business:

• files are removed from storage and we check that they are gone;
• we ask our email provider to delete contacts and check that they are gone. Delivery logs held by the provider follow the provider’s own retention schedule.

X- Users Outside of the United States

If you are a non-U.S. user of the Service, by visiting the Service and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your Personal Data, you consent to such transfer.

XI- Changes to This Privacy Policy

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy at https://earniverse.io/privacy-policy. The date the Privacy Policy was last revised is identified at the beginning of this Privacy Policy. You are responsible for periodically visiting our Service and this Privacy Policy to check for any changes.

XII- Questions

Contacting Earniverse; Reporting Violations; Requests from parents. If you have any questions, concerns or complaints about our Privacy Policy or our data collection or processing practices, if you want to exercise your rights, or if you want to report any security violation to us, you can reach us in any of these ways:

• Contact form: Contact Form
• Email: [email protected]
• Telephone: +1 650 912 5159
• Post: Earniverse, Inc., 254 Chapman Rd, Office 86, Suite 101B, Newark, DE 19702, USA

Parents of a child under 13 can use any of these channels. Before we act on a request about a child, we check that it comes from the child’s parent.

Copyright agent. To send us a written notice of copyright or trademark infringement, as described in our Terms of Service, please write to: Copyright Agent, Earniverse, Inc., 254 Chapman Rd, Office 86, Suite 101B, Newark, DE 19702, USA. Telephone: +1 650 912 5159. Email: [email protected].

Last Updated: October 23, 2026