Legal

PLACERION – TERMS AND CONDITIONS

These Terms and Conditions (“Terms”) govern your access to and use of the Placerion platform,
including the website, mobile application, digital collectibles (“Stamps”), Reward System,
ambassador program, and all related services (collectively, the “Platform”).
By creating an account or using the Platform, you agree to be bound by these Terms.

1. Operator & Introduction
   The Platform is operated by Placerion s.r.o., a company incorporated in the Czech Republic, with
   its registered office at Trojmezní 1877/12, Libeň, 190 00 Prague 9, Czech Republic, ID No.: 235
   86 338, registered with the Commercial Register maintained by the Municipal Court in Prague,
   File No. C 429689 (“Placerion”, “we”, “us”, “our”).
   These Terms constitute a legally binding agreement between you and Placerion.
   Your use of the Platform is also governed by our Privacy & Cookie Policy, which forms an
   integral part of these Terms.

2. Definitions
   User – any individual who creates an Account or uses the Platform.
   Account – a user profile created via email/password, Google, Apple, or other supported login
   methods.
   Stamp – a digital collectible purchased within the Platform and initially recorded off-chain in the
   User’s Account. A Stamp may optionally be minted by the User as a non-fungible token (NFT) on
   a supported blockchain.
   Off-chain Stamp – a Stamp existing solely within the Platform and not recorded on any
   blockchain.
   NFT (On-chain Stamp) – a Stamp that has been minted on a blockchain and transferred to a
   User’s Wallet.
   Wallet – a non-custodial cryptocurrency wallet controlled exclusively by the User.
   Reward System – a discretionary promotional and loyalty program distributing rewards to eligible
   Users holding minted Stamps, as described in Section 7.
   Ambassador – an individual or entity participating in Placerion’s ambassador program, where
   eligible, on terms communicated by, and agreed with, Placerion (see Section 8).
   Location Partner / Location – a physical venue offering Placerion Stamps via QR codes.
   Services – all features and functionalities provided through the Platform.
   Placerion may modify, limit, or discontinue Services at any time, subject to your mandatory rights
   under applicable law.

3. Eligibility & User Accounts

The Platform is intended for Users 16 years of age or older.
By using the Platform you represent and warrant that you have the legal capacity to enter into
these Terms or, where you are a minor permitted to use the Platform under applicable law, that
you do so with the consent and under the supervision of a parent or legal guardian who agrees to
these Terms on your behalf.
You may register using email and password, Google, Apple, or other third-party identity providers
supported by the Platform (e.g., Facebook, Discord, etc.).
You must provide accurate, current, and complete information when creating an Account.
You are responsible for maintaining the confidentiality of your login credentials.
Accounts are personal and non-transferable.
You are fully responsible for all activities conducted through your Account.
You represent that you are not located in, resident of, or acting on behalf of any country or
person subject to economic sanctions, embargoes, or similar restrictive measures imposed by
the EU, UN, the Czech Republic, or other applicable authorities, and that you are not listed on
any applicable sanctions list.
Placerion may suspend or terminate Accounts that violate these Terms or applicable law.
4. Nature of Placerion Stamps
4.1 Off-Chain First Model
All Stamps are initially created and delivered as off-chain digital collectibles stored in the User’s
Account, regardless of whether the purchase was made using fiat currency or cryptocurrency.
Until minted, a Stamp:
• exists solely within the Platform,
• is not a blockchain asset,
• cannot be transferred outside the Platform.
4.2 Optional Minting
Minting a Stamp as an NFT is:
• optional,
• initiated solely by the User,
• requires a connected Wallet and payment of applicable blockchain network fees.
Once minted:
• the Stamp becomes an NFT recorded on a blockchain,
• the User assumes full technical control and responsibility,
• blockchain transactions are irreversible and beyond Placerion’s control.
Placerion does not guarantee that minting functionality will be continuously available and
reserves the right to suspend or restrict minting due to technical, legal, or operational reasons.
Both forms are considered digital collectibles and function within the Platform for viewing and
collecting. However, only Stamps that have been minted as on-chain NFTs and are held in a
connected Wallet qualify for participation in the Reward System, as further described in these
Terms.

Purchasing or holding a Stamp does not grant the User any ownership, access rights,
governance rights, or legal interest in Placerion, any Location Partner, or any physical location
represented by the Stamp, unless stipulated otherwise by Placerion or the Location Partner.
4.3 No Financial Instrument
Stamps are digital collectibles intended for personal collecting and enjoyment. They are not
financial instruments, securities, transferable securities, units or participations in any collective
investment undertaking or fund, e-money, deposits, derivatives, or any other regulated financial
product, and they are not offered or sold as an investment.
You should not purchase or hold a Stamp with any expectation of profit, income, yield, return,
appreciation in value, or any other financial benefit.
Placerion makes no representation or guarantee regarding the value, price, liquidity, demand,
resale, or future utility of any Stamp, and the value of a Stamp may fall, including to zero.
The Reward System and any ambassador or location-based benefits are discretionary
promotional and loyalty features operated by Placerion in its discretion (see Sections 7 and 8).
They do not represent a share in Placerion’s profits, revenue, capital, or assets, do not constitute
a dividend, interest, coupon, or any return on an investment, and do not create any equity,
ownership, partnership, governance, or creditor relationship between you and Placerion.
5. Purchasing Stamps
5.1 Purchase Methods
Users may purchase Stamps using:
• fiat payment methods (e.g., card, Apple Pay, Google Pay), or
• supported cryptocurrencies.
Payment method does not affect the initial off-chain status of the Stamp.
5.2 Delivery
Upon successful payment:
• the Stamp is credited to the User’s Account as an off-chain Stamp,
• no Wallet is required to purchase or hold an off-chain Stamp.
5.3 Refunds
Subject to your mandatory consumer rights and Section 5.4:
• refunds may be limited or unavailable depending on payment method,
• cryptocurrency payments are non-refundable,
• QR codes at physical locations may occasionally malfunction or be inaccessible.
5.4 Right of Withdrawal (Consumers)
If you are a consumer in the EU/EEA, you generally have the right to withdraw from a contract for
the supply of digital content within 14 days without giving any reason.
Stamps are, however, supplied as digital content immediately upon payment. By completing a
purchase, you expressly request that Placerion begin supplying the Stamp immediately, and you
acknowledge and agree that you thereby lose your right of withdrawal once supply has begun.
Where the right of withdrawal has not been lost, you may exercise it by contacting us at
[email protected] before supply begins.

This Section does not affect any mandatory consumer rights that cannot be waived or limited
under applicable law.
6. Wallets, Minting & Transfers
Placerion is a non-custodial platform.
Users acknowledge that:
• they control their Wallet and private keys,
• Placerion cannot access, recover, or reset Wallet credentials,
• minted NFTs may be transferred, sold, or gifted externally,
• Placerion is not liable for wallet errors, incorrect transfers, hacks, loss of keys, or third-
party marketplace failures.
If a minted Stamp is transferred out of the User’s Wallet, it may lose eligibility for Platform-based
benefits.
Placerion is not liable for smart-contract failures, blockchain downtime, or network exploits.
Users bear the risk of theft, loss, or unauthorized access to their Wallet. Placerion cannot recover
access to your Stamps if you lose the Wallet or private keys.
7. Reward System
7.1 Reward Pool
Each calendar month, Placerion allocates 10% of Net Profit from Stamp sales to a Reward Pool.
“Net Profit” means the amount actually received by Placerion from Stamp purchasers, converted
into CZK or EUR using the exchange rate applied by the relevant payment processor, less
amounts deducted by such payment processor and other mandatory deductions (such as card
processing fees, currency conversion fees, chargebacks, refunds, blockchain network fees, and
similar transaction-related costs).
The Reward System is a discretionary promotional and loyalty mechanism. It is not an
investment product, financial service, profit-sharing arrangement, collective investment scheme,
or financial instrument, and participation does not give you any right to Placerion’s profits,
revenue, capital, or assets. Rewards are promotional benefits granted at Placerion’s discretion,
and Users have no vested or guaranteed entitlement to any reward until it has been validly
claimed, verified, and paid in accordance with these Terms.
Fraud, artificial activity, or abuse may result in exclusion from rewards.
Placerion may modify, suspend, or terminate the Reward System at any time.
Rewards may be claimed subject to minimum thresholds and payout schedules defined by the
Platform. Eligibility criteria may change.
7.2 Eligibility
A User is eligible for rewards only if:
• they hold one or more minted Stamps in their connected Wallet, and
• the Stamp is held during the relevant reward period.
Off-chain Stamps are not eligible for rewards.
7.3 Calculation & Claiming

Rewards are distributed proportionally based on holding duration:
• a full reward share if the Stamp is held for the entire month;
• a pro-rata share if held only part of the month, where: HoldingFactor = (days the Stamp is
held in the month) / (total days in the month).
For a given User (U), the monthly reward is calculated as:
Reward(U) = Reward Pool × ( Σ HoldingFactor of U’s qualifying Stamps ) / ( Σ HoldingFactor of

all qualifying Stamps across all Users )

The numerator is the sum of the HoldingFactors of the User’s own qualifying Stamps; the
denominator is the total holding time of all qualifying Stamps across all Users. This implements a
linear proportional model.
Users may request (claim) rewards at any time through the Platform. Payouts are processed
twice per month, specifically on the 15th day of each month and on the last day of each month.
The minimum claimable amount is 10 USD (or the equivalent in supported currencies).
Where a reward is paid out in a currency other than CZK, the amount is converted from CZK into
the relevant currency using the reference exchange rate published by the Czech National Bank
(ČNB) valid on the first day of the calendar month immediately following the month for which the
reward is paid.
Each User is responsible for any taxes arising from the receipt of rewards.
7.4 Verification, Withholding & Legal Compliance
Before processing any reward, payout, or withdrawal, Placerion may:
• (a) require you to confirm or verify your identity, age, eligibility, Wallet ownership, and the
source and legitimacy of your activity;
• (b) request any information or documentation that Placerion reasonably considers
necessary to comply with applicable law (including tax, anti-fraud, anti-money-laundering,
and sanctions requirements) or to protect the integrity of the Platform; and
• (c) delay, suspend, withhold, reduce, set off, or refuse any reward or payout, and/or
suspend or close your Account, where you fail to provide such information, where
Placerion reasonably suspects fraud, abuse, or unlawful activity, or where required or
permitted by applicable law or by a competent authority.
Placerion may disclose information to, and comply with lawful requests from, competent
authorities to the extent required by law. Placerion is not liable for any delay, withholding, or
refusal carried out in accordance with this Section.
8. Ambassador Program
Placerion may operate an ambassador program through which selected Users or third parties
(“Ambassadors”) promote the Platform and introduce new Locations to it.
Participation is at Placerion’s sole discretion and is subject to the separate terms agreed with the
relevant Ambassador.
Where an Ambassador introduces a Location to the Platform, the Ambassador may receive
rewards calculated by reference to the Stamps sold at that Location. The existence, nature,
amount, calculation, duration, and conditions of any such reward are determined by, and
governed by, the separate agreement entered into between Placerion, the relevant Location, and
the Ambassador.

Self-referral, fraud, manipulation, or artificial activity result in immediate disqualification and
forfeiture of any unpaid rewards.
Attribution of a Location to an Ambassador is based on the first valid introduction recorded by the
Platform. Placerion’s determination of eligibility is final, subject to the terms of any applicable
agreement.
Placerion may change, suspend, or discontinue the ambassador program at any time, subject to
the terms of any applicable agreement.
9. Location Partners
Location Partners are independent entities. Placerion is not liable for:
• QR placement or accuracy of information provided by the Location,
• physical access, opening hours, staffing, or safety of the location,
• any issues arising from the User’s visit.
Complaints about the physical venue must be resolved with the Location Partner directly.
10. Intellectual Property
All trademarks, software, code, design, databases, and materials on the Platform belong to
Placerion.
Users receive a limited, non-exclusive, non-commercial licence to use Stamp artwork for
personal display and sharing.
You may not copy, modify, distribute, or exploit Platform content without permission.
Users may not scrape, reverse-engineer, replicate, or disrupt the Platform.
Digital Stamps may contain artwork subject to separate licensing terms.
11. Prohibited Conduct
Users agree not to:
• violate laws or infringe the rights of others,
• create multiple accounts for abuse,
• manipulate the Reward System or the ambassador program,
• use bots or automation to purchase Stamps or claim rewards,
• spoof locations or fraudulently scan QR codes,
• circumvent security mechanisms,
• attempt to hack, disrupt, or reverse-engineer the Platform,
• upload harmful code, spam, or phishing,
• misrepresent their identity,
• engage in behaviour that harms Placerion, other users, or Location Partners.
Placerion may suspend accounts for violations.
12. Payments, Fees & Taxes
Fiat payments are processed by third-party providers (e.g., Stripe).
Crypto payments use supported blockchain networks.

Users are responsible for gas fees, blockchain fees, and third-party payment charges.
Users are fully responsible for compliance with applicable tax laws regarding purchases,
transfers, and rewards.
Placerion does not provide tax, financial, or investment advice.
13. Limitation of Liability
To the maximum extent permitted by law:
The Platform is provided “as is” and “as available”. Placerion does not guarantee uninterrupted or
error-free operation.
Placerion is not liable for:
• blockchain failures, smart-contract vulnerabilities, or network congestion,
• wallet compromise, lost private keys, or incorrect transfers,
• failure, error, or downtime of third-party providers,
• lost value or liquidity of digital collectibles,
• technical interruptions, bugs, or maintenance downtime,
• user mistakes (wrong Wallet address, failed transactions),
• force majeure events.
Total liability of Placerion in any 12-month period is limited to the amount you paid to Placerion
during that period.
Nothing in these Terms excludes or limits any liability that cannot be excluded or limited under
applicable mandatory law, including liability for death or personal injury caused by negligence, for
fraud or fraudulent misrepresentation, and any mandatory consumer rights that cannot be
waived.
14. Termination
Placerion may suspend or terminate your Account if:
• you violate these Terms,
• you violate applicable law,
• your actions or omissions create a security risk, fraud risk, or legal exposure for Placerion
or other Users, or
• Placerion is legally required to suspend or terminate the Account by a competent authority.
If your Account is terminated:
• you retain any Stamps already minted and stored in your Wallet, as these are fully under
your control;
• however, access to certain Platform features (including the Reward System, statistics,
collection views, minting of off-chain Stamps, or other services) may no longer be
available.
Placerion may, at its discretion:
• disable access to the Reward System or the ambassador program,
• revoke rewards not yet paid out, if you violate these Terms or if required by law.
15. Changes to the Terms

Placerion may modify these Terms at any time. Updated Terms become effective once
published.
For material changes, Placerion will take reasonable steps to notify you in advance (e.g., by
email or in-app message) and, where required by applicable law, will give you a reasonable
period before the changes take effect. If you do not agree with a material change, your remedy is
to stop using the Platform and, where applicable, to close your Account before the change takes
effect.
Your continued use of the Platform after the changes take effect constitutes acceptance of the
updated Terms, to the extent permitted by applicable law.
16. Governing Law
These Terms are governed by the laws of the Czech Republic.
The competent courts of the Czech Republic shall have jurisdiction over any dispute arising out
of or in connection with these Terms.
If you are a consumer, the above does not deprive you of the protection afforded by the
mandatory provisions of the law of your country of residence, and you may bring proceedings, or
be required to defend proceedings, in the courts of your country of residence where mandatory
law so provides.
Users may also seek out-of-court dispute resolution where applicable. In the Czech Republic, the
competent body for the out-of-court settlement of consumer disputes is the Czech Trade
Inspection Authority (Česká obchodní inspekce, www.coi.cz).
17. Contact
Placerion s.r.o.
[email protected]
www.placerion.com

PLACERION – PRIVACY & COOKIE POLICY
This Privacy & Cookie Policy explains how Placerion s.r.o. (“Placerion”, “we”, “us”, “our”) collects,
uses, and protects your personal data when you access or use our Services.
“Services” means all functionality made available by Placerion, including:
• the Placerion website at www.placerion.com, app.placerion.com, and any related
subdomains,
• our web and mobile applications (the “Platform”),
• user account management, wallet connection features, Stamp purchases (on-chain and
off-chain), minting, reward functionality, and the ambassador program,
• interactions with QR codes at partner locations,
• customer support, operational notifications, and service-related communications,
• optional marketing communications (where legally permitted),
• and any other digital features, tools, or services provided by Placerion now or in the future.

1. Controller
   Controller: Placerion s.r.o.
   Registered office: Trojmezní 1877/12, 190 00 Prague 9, Czech Republic
   Company ID: 235 86 338
   Email: [email protected]
   “Personal data” means any information relating to an identified or identifiable natural person
   under the EU General Data Protection Regulation (GDPR).
   We have not appointed a Data Protection Officer; you can contact us directly at the email above
   for any privacy-related questions.

2. What personal data we collect
   We process only the data that we reasonably need for the purposes described below.
   2.1 Account and profile data
   • First name and last name (if you choose to provide them or they are provided via social
   login),
   • email address,
   • password (hashed) if you register directly with us,
   • language and other profile settings (if applicable).
   2.2 Social login (Google, Apple, or other providers)
   If you sign in via any third-party identity provider, we may receive:
   • a unique identifier assigned by that provider,
   • your name (where provided),
   • your email address,
   • your profile picture or avatar (if the provider offers it and you grant permission).

We do not receive your password for any of these services, and we never gain access to your
credentials stored with those providers.
2.3 Wallet and blockchain data
When you connect a non-custodial wallet to your account on the Platform, we process:
• your public wallet address(es),
• information about Placerion-related NFTs (Stamps) associated with that wallet,
• blockchain transaction identifiers (transaction hashes) related to Placerion Stamp
purchases or other on-chain interactions with our Platform.
We do not store or have access to your private keys and cannot initiate transactions on your
behalf.
2.4 Stamp collection and location-related data
When you scan a QR code at a participating physical location and purchase or collect a
Placerion Stamp:
• we record which Location the Stamp belongs to,
• we record the time of collection/purchase,
• we link the Stamp to your Placerion account and, where applicable, to your wallet.
Where you give your explicit consent, we also process location data from your device at the
moment you collect or purchase a Stamp, in order to verify that you were physically present at
the relevant Location. Where verified, we record the fact that the Stamp was collected at that
Location and link this record to the Stamp and your Account.
We may use this verified-location record to enable certain Stamp-related benefits, rewards, or
features, now or in the future.
We do not track your location continuously or in the background. We process location data only
at the moment of collection and only with your consent. “Location” otherwise means the
participating venue (e.g., a specific museum, café, or sports venue) where you scanned the QR
code.
You can withdraw your consent to location processing at any time in your device or account
settings. Withdrawal does not affect the lawfulness of processing carried out before withdrawal,
and Stamps already recorded as verified retain that status. The legal basis for this processing is
your consent (Art. 6(1)(a) GDPR).
2.5 Payment and billing data
Card and similar payments (e.g., Apple Pay) are processed by Stripe or another integrated
payment provider.
We receive:
• partial card information (e.g., last four digits, card brand) if provided by the processor,
• payment status (paid / failed / refunded),
• amount, currency, time of payment,
• transaction identifiers from the payment provider,
• related billing information required by law.
We do not store full card numbers or CVV; these are processed directly by the payment provider.
2.6 Communication and support

If you contact us (e.g., via email, contact form, or in-app support), we process:
• your contact details (such as email and name, if provided),
• the content of your message and our replies,
• technical metadata (such as time, IP address, and system logs, where relevant and
technically necessary).
2.7 Marketing preferences and communication
If you opt in to receive marketing or product updates, we may process:
• your email address,
• your preferences regarding the type of updates you want to receive,
• simple metrics such as whether you opened our email or clicked on a link (where
enabled).
At this stage, we plan to send: onboarding emails; product and feature updates; information
about new locations or changes to the Platform.
2.8 Technical and usage data (including cookies)
When you visit our website or use the Platform, we automatically collect:
• IP address,
• browser type and version,
• device type, operating system,
• time and duration of visit,
• pages and screens viewed, buttons clicked, navigation patterns,
• referrer URL.
We collect this data via standard web technologies, including cookies and similar tools (see
Section 6).
2.9 Verification and compliance data
Where required by law, or to prevent fraud and abuse and to protect the integrity of the Platform,
we may process information you provide in order to verify your identity, age, eligibility, wallet
ownership, or the legitimacy of your activity (for example, before processing rewards or payouts
under Section 7.4 of the Terms). We collect such data only to the extent reasonably necessary
and retain it only for as long as required.
3. Purposes of processing and legal basis (GDPR)
We process your personal data only where we have a valid legal basis under GDPR. We rely on
the following legal bases: performance of a contract (Art. 6(1)(b)); legitimate interests (Art.
6(1)(f)); consent (Art. 6(1)(a)); and legal obligation (Art. 6(1)(c)).
The table below summarises what we do, why, and which legal basis we rely on:
Purpose What we do Main legal basis
Account creation and
login

Create and manage your Placerion account;
allow login via email/password, Google/Apple,
or other provider

Performance of a
contract
Wallet connection Link your non-custodial wallet to your account;

display your Placerion NFTs

Performance of a
contract; legitimate
interests (operating a
Web3 platform)

Stamp collection and
location linking

Let you scan QR codes at venues; record that
you collected a Stamp at a specific location and
time

Performance of a
contract; legitimate
interests (fraud
prevention, platform
integrity)

Location verification Confirm and record, with your consent, that a
Stamp was collected at a specific Location
while you were physically present; enable
location-based Stamp benefits/features

Consent (Art. 6(1)(a))

Payments and
invoicing

Process payments via Stripe; record
transactions; keep invoices

Performance of a
contract; legal
obligation (tax,
accounting)

Rewards, payouts and
verification

Operate the Reward System; process claims
and payouts; verify eligibility and prevent
fraud/abuse as set out in the Terms

Performance of a
contract; legitimate
interests; legal
obligation

Ambassador program Administer the ambassador program; attribute
introductions; calculate and pay agreed
rewards

Performance of a
contract; legitimate
interests

Communication and
support

Respond to your questions; handle support
requests and feedback

Performance of a
contract; legitimate
interests (service
quality)

Analytics and product
development

Analyse usage of the website and Platform;
improve features and UX

Legitimate interests;
consent where required
(non-essential analytics
cookies)

Security and abuse
prevention

Detect and prevent fraudulent or abusive
behaviour; secure accounts and infrastructure

Legitimate interests

Marketing
communication

Send you updates about new locations,
features, or Placerion news

Consent (Art. 6(1)(a));
limited legitimate
interests for service-
related
communications to
existing users

Legal compliance and
disputes

Comply with legal obligations; respond to
official requests; defend our rights

Legal obligation;
legitimate interests
When we rely on consent, you are always free to withdraw it at any time (see Section 11). When
we rely on legitimate interests, we have conducted a balancing test to ensure that our interests
do not override your fundamental rights and freedoms.
We do not use your personal data for automated decision-making or profiling that produces legal
or similarly significant effects on you within the meaning of Article 22 GDPR.
4. Recipients and third-party processors
We share personal data only where necessary and under appropriate contractual safeguards.
4.1 Infrastructure and hosting

We use Google Cloud Platform (GCP) or similar EU-compatible cloud infrastructure to host and
operate the Platform. Role: data processor. Data: account data, wallet and Stamp data, technical
logs, etc.
4.2 Payment processor – Stripe
We use Stripe (or a similar payment provider) to process card and related payments. Role:
independent controller and/or processor (depending on context). Data: payment details,
transaction metadata, status, partial card data. For more details, please see the privacy policy of
the relevant payment provider.
4.3 Analytics – e.g., Google Analytics
We may use Google Analytics 4 (GA4) or similar analytics tools to understand how users interact
with our website and Platform. GA4 is configured to anonymise IP addresses and does not allow
us to directly identify individual users. Data: IP address (which may be truncated), device details,
browser settings, pages visited, cookies. Role: processor or independent controller, depending
on configuration. Where required by law, we will request your consent before placing non-
essential analytics cookies.
4.4 Communication and email tools
We may use third-party services for transactional emails (account verification, security alerts),
product and update emails (where permitted), and support and ticketing systems. These
providers act as our processors and access your data only to the extent necessary to provide
their services.
4.5 Development and professional providers
We may share personal data with IT and development partners, security consultants, and legal
and accounting advisors. All such partners are bound by confidentiality and, where required, by
data processing agreements.
We do not sell your personal data.
5. International data transfers
Our operations are primarily based in the European Union. Some of our service providers (for
example, Google or Stripe) may process data in countries outside the EU/EEA, including the
United States.
When we transfer your personal data outside the EU/EEA, we ensure that there is an adequacy
decision by the European Commission, or that appropriate safeguards are in place, such as
Standard Contractual Clauses (SCCs), and, where necessary, additional technical and
organisational measures.
6. Cookies and similar technologies
6.1 What are cookies?
Cookies are small text files stored on your device when you visit our website or use our Platform.
They allow the site to recognise your device and remember information about your visit. We also
use other similar technologies (such as local storage, pixels, scripts), but for simplicity we refer to
them collectively as “cookies”. Cookies are not programs, cannot run code, or spread viruses on
their own.
6.2 Types of cookies we use

We use both session cookies (temporary cookies deleted when you close your browser) and
persistent cookies (which remain on your device for a defined period or until you delete them).
Depending on their purpose, our cookies fall into the following categories:
(a) Strictly necessary cookies
These cookies are essential for the operation of the website and Platform: navigating the
website, logging into secure areas, keeping your session active, and maintaining security and
preventing abuse. Without these cookies, some services cannot be provided. They do not require
consent under GDPR, but you can still block them in your browser (though the site may not work
properly).
(b) Functional / preference cookies
These cookies remember your choices (such as language or display settings), improve your user
experience, and may store whether you have already seen or accepted certain notices. If these
cookies are not strictly necessary, we rely on your consent where required by law.
(c) Analytics cookies
Analytics cookies help us understand how many visitors we have, which pages are most
frequently visited, how users move around the website, and what we should improve. We may
use tools such as Google Analytics. Where required by law, we ask for your consent before using
analytics cookies, and data collection may be limited or adjusted based on your consent
preferences.
(d) Marketing / tracking cookies (if used)
If we ever use cookies for marketing, retargeting, or tracking across sites, these will be used only
with your explicit consent and will be clearly described (including the third parties involved).
Currently, Placerion does not rely on aggressive advertising technologies such as third-party ad
networks on our main Platform, but this may change in the future. If it does, we will update this
Policy and request your consent as required.
6.3 How we use cookie data
Using cookies, we may keep you logged in while you browse the Platform, remember your
language and other preferences, secure your session and prevent misuse, and generate
anonymised or aggregated statistics about usage. We do not use cookies to identify you
personally in a way that would allow us to track your broader web activity outside our Platform.
6.4 Managing cookies
You can manage cookies via your browser settings (block all cookies, block only certain types, or
delete stored cookies), via our cookie banner / preference centre where provided, and via third-
party opt-out tools (for example, Google’s opt-out browser add-on for Analytics). If you disable or
reject cookies, some features of the website or Platform may not function properly. Where
required by law, non-essential cookies are used only after you provide your explicit consent via
our cookie banner or preference centre.
7. How long we keep your data
We keep your personal data only for as long as necessary for the purposes for which it was
collected, or as long as required by law. In particular:
• Account and profile data: stored for as long as you have an active account. Once you
delete your account, we delete or anonymise these data, unless we must keep some
information for legal reasons.

• Wallet and Stamp data (off-chain records): stored for as long as you maintain your
account, to display your collection and ensure the proper functioning of the Platform. After
account deletion, we anonymise or remove personal links to the extent possible.
• Blockchain data (on-chain): transactions and public addresses recorded on the blockchain
cannot be changed or deleted by us. We minimise our off-chain processing of this data
and limit links to your identity. We do not control public blockchains and are not a
controller of personal data independently published on such blockchains.
• Payment and billing data: kept for the period required by law (e.g., tax and accounting
rules), typically several years after the relevant transaction.
• Verification and compliance data: kept only for as long as required to fulfil the relevant
legal or fraud-prevention purpose, and then deleted or anonymised.
• Communication and support data: kept for the time necessary to handle your request and,
where appropriate, for a reasonable period to protect our legal interests.
• Marketing data: kept until you withdraw your consent or object to processing, or for the
maximum period allowed by law for such activities.
• Cookies and analytics: stored according to their specific lifetime (session or persistent),
which you can also influence via your browser and preferences.
Once the relevant retention period expires, we delete or irreversibly anonymise your data.
8. Security of your data
We implement appropriate technical and organisational measures to protect your personal data,
including encryption in transit (e.g., HTTPS) and, where appropriate, at rest; access controls and
authentication for staff and systems; regular software updates and security patches; backups and
monitoring; and internal policies and training for personnel with access to personal data.
No system is completely secure, and we cannot guarantee absolute protection. However, we do
our best to safeguard your data.
You are responsible for choosing a strong and unique password, keeping your login details
confidential, protecting your wallet and private keys, and using up-to-date software and security
measures on your device.
9. Children and minors
The Platform is not intended for children under 16 years of age.
By creating an account and using the Platform, you confirm that you are at least 16 years old, or
that you are using the Platform with the consent and supervision of a parent or legal guardian.
We do not knowingly collect personal data from children under 16. If we learn that such data has
been collected, we will delete it as soon as reasonably possible.
10. Your rights under GDPR
Under GDPR, you have the following rights (subject to legal conditions and exceptions):
• Right of access – confirmation whether we process your personal data and a copy of such
data.
• Right to rectification – correction of inaccurate or incomplete personal data.

• Right to erasure (“right to be forgotten”) – deletion of your personal data in certain cases.
This does not apply to data we must retain by law or data stored on public blockchains,
which we cannot alter.
• Right to restriction of processing – in certain situations (e.g., while we verify accuracy).
• Right to data portability – receive your personal data in a structured, commonly used,
machine-readable format and, where technically possible, transmit it to another controller.
• Right to object – object at any time to processing based on our legitimate interests,
including profiling on that basis; you can always object to direct marketing.
• Right to withdraw consent – where processing is based on consent, you can withdraw it at
any time, without affecting the lawfulness of processing before withdrawal.
• Right to lodge a complaint – with your local data protection authority. In the Czech
Republic, this is the Úřad pro ochranu osobních údajů (UOOU) – www.uoou.cz.
11. How to exercise your rights
To exercise any of your rights, please contact us at: [email protected], or by post at Placerion
s.r.o., Trojmezní 1877/12, 190 00 Prague 9, Czech Republic.
We may need to verify your identity (for example, by asking you to log in to your account or
provide certain information) to prevent unauthorised access to your data.
We will respond to your request within one month of receipt. In complex cases, this period may
be extended by up to two further months; if so, we will inform you about the extension and the
reasons.
12. External links and third-party sites
The Platform may contain links to third-party websites or services (e.g., wallet providers, partner
locations, social networks, block explorers). We are not responsible for the privacy practices or
content of such third-party sites. We recommend that you review their privacy policies before
providing any personal data.
13. Changes to this Policy
We may update this Privacy & Cookie Policy from time to time, for example to reflect changes to
our services, to comply with new legal or regulatory requirements, or to clarify text or improve
transparency.
The updated version will be published on our website with an updated “Last updated” date. For
material changes, we may also notify you via email or in-app notification. We encourage you to
review this Policy periodically.
14. Contact
If you have any questions, comments, or concerns regarding this Privacy & Cookie Policy or our
data practices, please contact us:
Placerion s.r.o.
Registered office: Trojmezní 1877/12, 190 00 Prague 9, Czech Republic
Company ID: 235 86 338
Email: [email protected]