Privacy Policy


This Privacy Policy describes how Awaken (herein referred to as "We", "Our", and "Us") collects, uses, processes, discloses, shares, transfers, and protects the information You provide on website. We respect and appreciate your privacy and the integrity of the information you provide and allow us to collect. We strive to adhere to industry standards to ensure the security and confidentiality of your Personal Information when you use our services or access the Awaken platform and ecosystem. If you access, connect to, use, click on or participate in any service provided by Awaken, we strongly encourage you to carefully read, acknowledge, understand and accept all of the terms of the Privacy Policy. We will not use your information in any form or other purpose not outlined in this Privacy Policy without your prior notice or consent. This Privacy Policy has incorporated several provisions from the General Data Protection Regulation ("GDPR"), explicitly following its Personal Information Processing rules within the European Economic Area ("EEA"). This privacy policy will keep you informed of the following Information:

1. Acceptance of the Privacy Policy

2. Our Relationship with You

3. Personal Information that We collect

4. How We collect Personal Information

5. How We use Personal Information

6. How We Protect Personal Information

7. How long We retain Personal Information

8. Cookies

9. Sharing your Personal Information

10. Third-Party Collection of Personal Information

11. Designated Countries and Your Legal Rights

12. Rights of the residents of the EEA

13. Cross-Border Transfer of Personal Information

14. Limitations

15. Updates or amendments to the Privacy Policy

16. How to contact Awaken

1. Acceptance of the Privacy Policy

By accessing, connecting, clicking on, using, or engaging in Our Services, You indicate and confirm that You have consented and agreed to this Privacy Policy. We will not use your Personal Information for any other purpose not covered by this Privacy Policy or the Terms and Conditions without your prior notice or consent. If you do not fully or partially agree to this Privacy Policy, you must immediately terminate access, connection, use, or participation in our services and the Awaken platform. This Privacy Policy does not apply to services offered by other companies or service providers or other websites linked to our ecosystem.

2. Our relationship with you

Awaken has individual relationships with its services, as described below:

• "User" is an individual who provides us with Personal Information through our Awaken website, Official Channels, social media accounts, or other means. For example, users can create and complete other Awaken social media engagement tasks, gain the right to add a whitelist for any IDO fundraising activity, or communicate with us on our social media accounts.

• In addition, we may refer to "User" as "You" in this Privacy Policy

3. Personal Information that we collect

For this Privacy Policy, Personal Information is data used to identify, describe, relate, or associate with a particular individual. The following are the types of information We collect, store, and process when You use Our services:

Information collected by Us as You use Our services

Usage Information

When You engage or use Our Services, We will monitor your information through your device, such as your IP address, phone number, the type of device You use to access Our Platform, device information, which websites You visited before accessing Our Services or Platform, browser type, Information about your browser, Date and Time You visit Our Platform, Volume of data transmitted and network operator. This information will be directly obtained by Awaken or through third-party service providers. We collect this information to ensure that Our interface and Platform are seamlessly accessible for all worldwide users, except users in prohibited jurisdictions.

Communication Information

We are entitled to collect and use or process the Personal Information You have provided on Our Platform or generated through your usage of the Awaken ecosystem to be able to communicate with You through messages, requests, emails, live chats, file attachments in connection with your transactions on Awaken, or any other information related to your contact with us. If You contact Us, We will keep a record of the information shared during the correspondence.

Financial Information

For the purposes stipulated in this Privacy Policy, We are entitled to collect and use the information contained in or related to your financial Information when You use Our services. Without limitation, your transaction history includes your initial cryptocurrency or token amount, your Awaken Token ($AWG) amount, your staking instructions, and your wallet address. We collect this financial information to monitor suspicious economic activities to protect You from fraud, resolution of legal cases, as well as any other purposes disclosed in this Privacy Policy. Parts of Awaken Services are public, including any information disclosed on Our social media accounts. Thus You acknowledge that such aspects of Awaken Services may appear on search engines or other publicly available platforms and may be "crawled", searched, and used by the third parties or other Users and Customers of the Services. Please do not post any information that You do not wish to reveal publicly.

4. How We collect Personal Information

We automatically collect information.

We will collect and process Personal Information automatically provided by You under the following situations.

  • when You visit and firstly connect with Awaken website;

  • when You voluntarily complete any user survey or provide feedback to Us via emails or any other electronic channels, including on Our social media accounts;

  • when You use browser cookies or any other relevant software upon visiting Awaken website;

  • Other situations where We may automatically collect your information as described in this Privacy Policy, Our T&Cs, or other relevant agreements with You.

Information collected by the third-party

We will collect your Personal Information from third parties as required or permitted to the extent of applicable laws. Information from the third-party sources will include, but will not limit to, public databases, ID verification partners, KYC Verification partners, blockchain data, marketing partners and resellers, advertising partners, and analytics providers.

Anonymized and Aggregated Data

We will also collect other information in the form of anonymized and aggregate information where all data will be combined and then removed of personally identifiable information, making it unusable to identify specific individuals. Aggregated Data could be derived from your data, but it is not considered personal data under applicable laws. For example, We may aggregate your usage data to calculate the percentage of users accessing specific features of Awaken Ecosystem. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify You, You acknowledge that we treat the combined data as personal data, which will be used following this Privacy Policy.We use anonymized or aggregate users' information for the purposes stipulated in this Privacy Policy at any time, including gaining a better understanding of users' needs and behaviors, conducting business intelligence and marketing initiatives, and detecting security threats. In this regard, We reserve the right to implement innovative technologies as they become available for strategic planning and operational processes.

5. How We use Personal Information

Your Personal Information will be made available on a need-to-know basis to Awaken, Our Affiliates, Our Partners, or within Our group of companies. The employees or any persons or third parties working for Awaken are responsible for using and protecting your Personal Information. We use and process your Personal Information for the following purposes or in the following ways:

To provide Our Services

We respect data protection principles and process personal data only for specified, explicit, and legitimate purpose for which such personal data were provided. We primarily use your Personal Information, either collected or delivered, to enable your use of the Awaken platform and ecosystem (including, but not limited to, processing transactions) to improve the Services' efficiency and the process to participate in the IDO fundraising events and to verify your identity.

To protect users

We use the information collected to protect Our Platforms, Users' Information, and archives. We also use IP addresses and cookies to detect suspicious activities and protect against automated abuse such as spam, phishing, Distributed Denial of Service ("DDoS") attacks, and other security risks.

To comply with regulations and compliance

For Our legitimate interests, We will use the information in compliance with Our legal obligations, global and local industry standards, and Our AML/KYC/CTF procedures. In the case where it is strictly necessary (i.e., to protect the vital interests of the users or other natural persons, to prevent or mitigate fraud, to fulfill the purpose of public interest, or to pursue Our reasonable interests), We may use and process your Personal Information without obtaining your consent. You hereby expressly authorize Awaken to disclose all information relating to You in Awaken's possession to any law enforcement or government officials upon a valid request.

For measurement, research, and development purposes

  • We actively measure and analyze your information to understand how You use and interact with Our Services and Our Platform and provide You with a unique and personalized experience. For example, We allow You to use social media plugins on Our Services (e.g., Telegram, Twitter). We keep track of your preferences such as display name, time zone, etc. This review is continuously conducted by Our operation teams to improve Our Platforms' performance constantly and to resolve issues with user experience.

  • In addition, We use such information to monitor trends, improve Our Services, Our administration, the content and layout of the Awaken website, and develop new Services for You.

For communication purposes

  • We use your Personal Information, collected or derived from your communication devices or email address, to interact with You directly, provide You with the necessary support, and keep You informed of wallets connected, transactions, staking instructions, and security details as well as other aspects.

  • All direct communications will be appropriately maintained at Awaken, or the service providers designated by Us, to be reviewed for accuracy, retained as evidence or used to perform other statutory requirements or other obligations as stipulated in this Privacy Policy and the T&Cs.

For marketing and advertising

  • We will share your Personal Information with Our marketing partners for the purposes of targeting, modelling, or identifying analytics as well as marketing and advertising. We may send You marketing communications to alert You about new Services, yet You can opt out of Our marketing activities at any time.

For other purposes

  • Provided that we need to process or use your Personal Information for other purposes not stipulated in this Privacy Policy, We will notify or request your consent to use such information. We will not use your Personal Information for purposes other than the purposes stipulated in this Privacy Policy without your prior consent except where it is necessary for our legitimate interests (or for Our Affiliates, Our Partners, and Our group of companies) and your interests and fundamental rights do not override those interests.

6. How We protect Personal Information

Awaken takes reasonable care to protect our security as well as your Personal Information from loss, misuse, disclosure, alteration, and destruction. We maintain physical, technical, and procedural safeguards to ensure your information confidentiality and integrity. The safeguards include the use of firewalls, and data encryption, enforcing physical access controls to Our premises and files, and limiting access to Personal Information only to those employees, agents, or third parties who need access to that information to process it for Us. We also implement specific reasonable security measures to protect your Personal Information from unauthorized access, and such security measures comply with the security practices and procedures as prescribed under the applicable laws.However, You agree and acknowledge that it is impossible to fully guarantee the security of your Personal Information by implementing the safeguard mentioned above and measures. It is not absolute protection to your Personal Information and accessing the Services. You agree that We will not hold any responsibility for the acts committed by those who gain unauthorized access or abuse your information and services. In addition, We will not have any responsibility for any act committed by the third-party service providers who are contractually engaged with Us to maintain an appropriate security measure for protecting your Personal Information. Thus, You are recommended to understand this responsibility and independently take safety precautions to protect your Personal Information, mainly your credential information such as your wallet address. You hereby agree that We will not be liable for any information leakage and other damage or loss not caused by Our intention or gross negligence, including, but not limited to, hacker attacks, power interruptions, or unavoidable technical failures.

7. How long We retain Personal Information

You are aware that your Personal Information will continue to be stored and retained by Us or by a third-party processor engaged by the US for KYC Verification while You have been using or accessing the Awaken ecosystem and the Services and after your use of the Services for a reasonable time stipulated under the applicable law. In addition, We may be required by applicable laws and regulatory requirements to retain certain information, including your Personal Information, your identification verification materials, Information relevant to AML/KYC/CTF procedures, Information related to staking instructions, account agreements, and other agreements between Us and third-parties, account statements, and other records after You stop accessing or participating in Awaken.

8. Cookies

We will use cookies and other technologies or methods of web and analytic tools to gather, store, and analyze certain information related to your access to and activities through the Services, including when You visit Awaken website. A "cookie" is a small piece of information that a website assigns to your device while You are viewing a website. Cookies are beneficial and may be used for various purposes. These purposes include, among other things, allowing You to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences, and making the interaction between You and the Services quicker, easier and smoother. Our Awaken website will use the following types of cookies:

Strictly Necessary Cookies

These cookies are essential to enable You to log in, navigate a website, and use its features or provide a service requested by You. We will not need to obtain your consent to use these cookies.

Functionality Cookies

These cookies allow the website to remember your choices (such as your username, language, or the region You reside in) and provide enhanced, more personal features. The information these cookies collect remains anonymous, and they cannot track your browsing activity on other websites.

Performance cookies

These cookies collect information about how You use a website, for example, which pages You go to most often, how much time You spend on a page, and record difficulties You may experience while using the website, such as error messages. All information collected by these cookies is aggregated and therefore anonymous. It is only used to improve the efficiency of the website.

Targeting Cookies or Advertising Cookies

  • These cookies are used to deliver advertisements tailored to You and your interests precisely. They are also used to limit the number of times that You see an advertisement as well as help measure the effectiveness of the advertising campaign. These cookies remember that You have visited a website, and this information is shared with other organizations such as advertisers. Often targeting or advertising cookies will be linked to the sites' functionality provided by the other organizations.

  • You may remove these cookies by following the instructions of your device preferences. However, if You choose to disable cookies, some features of Awaken Services may not operate correctly or become inaccessible, and your online experience may be limited.

9. Sharing your Personal Information

We will not rent, sell, or disclose your Personal Information to any third parties, except to those who require access to the information to perform their tasks and duties under the binding agreements executed with Us and share with third parties who have a legitimate purpose for accessing it.We may share, transfer, disclose, or allow access to your Personal Information to the following third parties for the purposes described below:

  • We may disclose Personal Information to the third parties in order to administer or process a transaction or services You have authorized or requested or in the context of facilitating the execution of a transaction. We may disclose Personal Information to third parties that provide support services or analytical information for the Service improvement only where we have a lawful basis to do so or under an agreement or legal requirements for the transfer of Personal Information.

  • We will be required to verify your identities by applicable laws and regulatory requirements and rely on third-party services to perform these verifications. Personal Information You Provide to Us during the initial connecting process is passed to these services at KYC Verification process and on an ongoing basis after that.

  • We may disclose or transfer a part of the Personal Information We collect if We are involved in a business transition or any merger and acquisition (M&A) projects. In such an M & M&A event, your Personal Information might be among the assets transferred, but it will be protected and secure according to this Privacy Policy.

  • We may share your Personal Information with law enforcement and government officials when We are compelled to do so by a subpoena, a valid court order to prevent financial loss, report suspected illegal activity, or investigate violations of any of Our T&Cs or any other applicable policies.

  • We may share your Personal Information with third-party processors acting on behalf of Awaken or engaged by Awaken to process your Personal Information for Awaken, Our Affiliates, and Our Partners.

  • All Affiliates and third parties with whom We share your Personal Information have their privacy policies. However, they will be expected to protect this information in a manner that aligns with the provisions described in this Privacy Policy.

10. Third-Party Collection of Personal Information

This Privacy Policy only addresses the use and disclosure of the Personal Information We collect from You. To the extent that You disclose your information to other parties through our Services, such as by clicking on a link to any other websites of our partner networks, different rules regarding Privacy Policies may apply to their use or disclosure of the Personal Information You disclose to them.You hereby acknowledge that We will not be responsible for the products, services, or descriptions of products or services that You receive from the third-party websites or to the content or privacy practices of the third-party websites. Also, this Privacy Policy will not be applied to any such third-party products and services that You access through Awaken ecosystem. You are knowingly and voluntarily assuming all risks of using third-party websites to purchase products or services, and You agree that We will have no liability whatsoever concerning such third-party websites and your usage of them.Your relationship with these third parties and their services and tools is independent of your relationship with Us. These third parties may allow You to permit/restrict the collected information. It may be in your interest to restrict or enable such data collections individually.

This provision applies to Users of the Services located in the EEA, United Kingdom, and Switzerland (herein collectively referred to as "Designated Countries") when Data or Personal Information is collected. We may ask for your information regarding your nationality, location, and country You are in when You use Our Services or Platform, or We may rely on your IP address. We cannot apply this provision to Users who do not provide information about the location or obfuscate location information not to appear located in the Designated Countries. We use and process your Personal Information based on a valid lawful basis of the GDPR and any equivalent regulations (collectively referred to as "Data Protection Laws"). The lawful basis for processing your Personal Information includes

  1. Your consent

  2. Performance of a contract

  3. A legitimate interest

  4. A compliance with legal obligations

  5. Protection your vital interest

  6. Public task

In the event of any conflict or inconsistency between any term in this provision and other terms in this Privacy Policy, the term in this provision will govern and control users in the Designated Countries.Under certain circumstances, when You use Our Services, You have the rights under the Data Protection Laws about your Personal Information. These rights include the following:

Right to be informed

You reserve the right to be informed about the collection, use, and process of your Personal Information.

Right of access

You reserve the right to make a request for a copy of the Personal Information We hold about You and specific Information regarding Our processing of this information.

Right to rectify

You reserve the right to request Us to update, correct, or complete your Personal Information that You believe to be outdated, inaccurate, or incomplete. You will rectify this at any time by informing Us via our contact channels.

Right to erasure ("Right to be Forgotten")

You may request to have your Personal Information deleted from Our record where your Personal Information is no longer necessary to be used for the Services or on the Platform; your Personal Information was collected in relation to processing that You previously consented to but later withdrew or your Personal Information was collected in relation to processing activities to which You object, and there are no overriding legitimate grounds for Our processing.

  • Please be informed that the right to be Forgotten mentioned above is not an absolute right. We are compelled to fulfill your request only where the retention of your Personal Information might cause an infraction of the GDPR or applicable law to which We are subject. We shall exercise reasonable efforts in having your Personal Information erased to the extent required by the GDPR or applicable law, including in communicating erasure to Our recipients of your Personal Information unless that proves to be impossible or a disproportionate effort.

Right to data portability

  • You reserve the right to request to transfer a machine-readable copy of your Personal Information to You or the third party of your choice. We will provide You, or a third-party, your Personal Information in a machine-readable format. This right only applies to Personal Information You have consented Us to use.

Right to restrict processing

You may request Us to restrict or suppress the processing of your Personal Information under certain circumstances as follows:

  • to contest the accuracy of the Personal Information;

  • when the processing is considered unlawful, but You do not wish to have your Personal Information erased;

  • where We no longer need to process your Personal Information, but the information must be retained for the establishment, exercise or defense of legal claims; and

  • where You have objected to Our processing your Personal Information, but We need to determine whether Our legitimate interest overrides your objection.

Right to object

You may object to Our reliance on Our legitimate interests as the basis of Our processing of your Personal Information that impacts your rights. You may also object to Our process of your Personal Information for direct marketing purposes.

  • You reserve the right to withdraw your consent when we are relying on it to process your Personal Information. Withdrawing your consent does not affect the lawfulness of Our processing of your Personal Information prior to withdrawing.

  • If You wish to exercise these rights as aforementioned, please inform and contact Us via Our Platform, including Awaken website or send a request to Contact Support.

  • There are some limitations when You wish to exercise any of these individual rights. We may limit your rights in the following situations:

  • Where denial of access is required by-laws;

  • When granting access would harm others' privacy;

  • In order to protect Our rights and properties;

12. Cross Border Transfer of Personal Information

As a part of your use of and to ensure better and seamless delivery of the Services to You, We may store, process, analyse, transfer your Personal Information in location globally, including countries other than your home jurisdiction, and/or locations outside the Designated Countries where there may have data protections with less protection than the EU GDPR or the equivalent data protection laws.Our Service and Platform contain the transmission of your Personal Information to or to be transferred to or processed outside of the country where You are located or outside the Designated Countries; it is not suggestible if your Personal Information is restrictive.

13. Limitation

  • Our Services are not designed for people under 18 or under the legal age to provide consent under the applicable laws of the country or jurisdiction where You are using Our Services or Platform. If You are not over 18 or of your country's legal age, You will not provide any Personal Information to Us or engage in Our services. We reserve the right to access and verify any Personal Information collected from You. If We are aware that You are under 18 or under the legal age who already shared your Personal Information with Us, We will discard such information and block your access to the Awaken ecosystem immediately.

  • We cannot guarantee that any losses, misuses, unauthorized accession, or alteration of your Personal Information will not occur. You hereby agree that You play a vital role in protecting your Personal Information, including your credentials.

14. Updates or amendments to the Privacy Policy

We will revise and update this Privacy Policy periodically, at Our sole discretion, and the most current version will be published on Awaken website or ecosystem.In the event of any material change that may affect your use of Our Services and Platform, We will notify You by a prominent notice in advance of such change coming into effect. A major amount of information may include sending through your email address or other communication channels. We strongly encourage You to review this Privacy Policy actively. If You disagree with the revised Privacy Policy, You should discontinue accessing or using Our Services. Your continued access to our Awaken ecosystem after any changes to this Privacy Policy constitutes your consent to any changes and agree to continue using the Services.Furthermore, We may provide You with the “just-in-time” disclosures or additional information about Our data collection process, purposes for processing, or other information. The just-in-time notification aims to supplement or clarify Our privacy practice or provide You with additional choices about how We process your personal information.

15. How to contact Awaken

For any questions regarding this Privacy Policy, your Personal Information collected or proceeded by Us, or in case You would like to exercise one of your legal privacy rights as stipulated in Clause 11, please submit your requests to Contact Support and visit Our website.

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