Effective Date: December 20, 2024

Tabula Rasa Limited (“TRLab,” “we,” “our,” or “us”) provides this Privacy Policy (“Privacy Policy”) to describe how TRLab collects, uses, and shares the information of individuals who visit our website located at https://trlab.com (the “Site”) and our mobile applications (the “Properties”) and sell, purchase, mint, and display non-fungible tokens (each, an “NFT”) through our Site (collectively, the “Services”).

Information Collection

When using our Services, you may provide information about yourself, including your name, contact information, and any other information you choose to provide. For example, we collect this information when you join our email list, create an account or a profile, contact us, or interact with us for any other purpose. When you create an account or profile, we will also collect your email address, log-in information, phone number, profile picture, mailing address, information about your digital wallet, credit card information, and any other information you choose to provide. We may also collect information required to pass “Know-Your-Customer” (“KYC”) requirements, such as a copy of your government-issued photo ID, proof of address, bank references, and information related to your digital wallet. We may also combine the information you provide with information we collect from our third-party verified partners.

We (and other entities) automatically collect information relating to your interactions with us and our Services, including browser type, IP address, pages visited, and other activities on the Services, device type, and time and date of visit, device identifiers, and other information we collect through the use of cookies and similar technology. See the “Analytics” section of this Privacy Policy to learn more about the use of this information and the choices available to you.

Information Use

We may use your information for any lawful purpose, including the following:

To fulfill your purchases;
To respond to your inquiries;
To support gameplay in our Properties;
To facilitate rewards programs on our Properties;
To enable you to offer NFT art through our Services;
To verify your information so that you may bid, buy, and sell NFT art through our Services;
To operate, personalize, and improve the Services, including for analytics purposes;
To promote and market our products and services, including to send updates, promotions, advertisements, and marketing materials that may be of interest to you;
To comply with the law and to maintain the security of our Services; or
With your consent, or as otherwise disclosed at the time information is collected.

We may use information that has been de-identified or aggregated without limitation.

Information Sharing

We may share the information we collect with other parties, including the following:

With our partner artists;
With custody partners;
With third-party partners we rely on to verify your identity and to administer KYC review, such as Amber;
With third-party service providers who process information on our behalf, such as payment processors, data hosting services, and email service providers, or with our legal or business advisors;
With any partners, affiliates, or joint venture partners that we have now or may have in the future;
As part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets, including as part of a bankruptcy proceeding;
Pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law, to protect our rights or the rights of third parties, or to protect the safety or security of any person or entity; or
With your consent or as otherwise disclosed at the time of data collection or sharing.

We may share information that has been de-identified or aggregated without limitation.

The Services may offer interactive features, such as the ability to place bids on NFT art, that you can use to communicate with other Services users. For instance, when you place a bid, the bid amount will be made available to other Services users. If you disclose information through such features, the information you provide can be viewed, collected, and used by others.

Digital Advertising & Analytics

We may partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Site, Applications, and other sites or apps over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.

You may visit the DAA Webchoices tool at http://www.aboutads.info to learn more about this type of advertising and how to opt out of this advertising on websites by companies participating in the DAA self-regulatory program. You can also exercise choices regarding interest-based advertising on your mobile device by downloading the appropriate version of the DAA’s AppChoices tool at https://youradchoices.com/appchoices.

If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choices exercised through the DAA Webchoices tool. Note that electing to opt out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests.

We may work with third parties that collect data about your use of the Services and other sites or apps over time for non-advertising purposes. We use Google Analytics and other third-party services to improve the performance of the Services and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Services, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.

Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, our Services may not function as intended.

Third-Party Links and Tools

The Services may provide links to third-party websites or apps. We do not control the privacy practices of those websites or apps, and they are not covered by this Privacy Policy. You should review the privacy policies of other websites or apps that you use to learn about their data practices.

The Services also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share personal information or you otherwise interact with these features on the Services, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public.

Your interactions with third-party companies and your use of their features are governed by the privacy policies of the companies that provide those features. We encourage you to carefully read the privacy policies of any accounts you create and use.

California Privacy Rights

This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the CCPA.

Personal Information We Collect. In the preceding 12 months, we collected the following categories of personal information about California consumers.

Categories of Personal Information	Disclosed for business purposes to the following categories of third parties:	Sold or Shared to following categories of third parties:
Personal and online identifiers (such as first and last name, email address, or unique online identifiers)	Service providers; Custody partners; Verification partners; Partner artists; Digital experience partners; Affiliates not under the TRLab brand; and Government entities	Partner artists; Digital experience partners; and Affiliates not under the TRLab brand.
Categories of information described in Section 1798.80(e) of the California Civil Code (such as address, credit card number, bank account number, and other financial information)	Service providers; Custody partners; Verification partners; Partner artists; Digital experience partners Affiliates not under the TRLab brand; and Government entities	Not sold.
Commercial or transactions information (such as records of personal property or products or services purchased, obtained, or considered)	Service providers; Custody partners; Verification partners; Partner artists; Affiliates not under the TRLab brand; and Government entities	Partner artists; and Affiliates not under the TRLab brand.
Internet or other electronic network activity information (such as browsing history or interactions with a website, email, application, or advertisement)	Service providers; Custody partners; Verification partners; Partner artists; Affiliates not under the TRLab brand; and Government entities	Partner artists; and Affiliates not under the TRLab brand.
Geolocation information	Service providers; Custody partners; Verification partners; Partner artists; Affiliates not under the TRLab brand; and Government entities	Partner artists; and Affiliates not under the TRLab brand.
Sensory information (such as audio, electronic, visual, thermal, olfactory, or similar information)	Service providers; Custody partners; Verification partners; Partner artists; Affiliates not under the TRLab brand; and Government entities	Partner artists; and Affiliates not under the TRLab brand.
Other information about you that is linked to the personal information above	Service providers; Custody partners; Verification partners; Partner artists; Digital experience partners; Affiliates not under the TRLab brand; and Government entities	Partner artists; and Affiliates not under the TRLab brand.

Some of the categories of personal information listed above are considered sensitive personal information under the CCPA. We do not use or disclose sensitive personal information, as defined by the CCPA, for purposes other than those specified in the CCPA.

Categories of Sources. We collect personal information from the following categories of sources:

Consumers;
Service providers;
Custody partners;
Verification partners;
Business partners;
Advertising companies and networks;
Banks;
Affiliates not under the TRLab brand;
Joint venture partners; and
Government entities.

Why We Collect, Use, and Share California Information. We use and disclose the personal information we collect for our commercial and business purposes, as further described in this Privacy Policy. These commercial and business purposes include, without limitation:

Our commercial purposes, including enabling commercial transactions, marketing, and advertising.
Our business purposes as identified in the CCPA, which include:

Auditing related to our interactions with you;
Legal compliance;
Detecting and protecting against security incidents, fraud, and illegal activity;
Debugging;
Performing services (for us or our service provider(s)) such as account servicing, processing orders and payments, and analytics;
Internal research for technological improvement;
Internal operations;
Activities to maintain and improve our services; and
Other one-time uses.

We may also use and share aggregated and de-identified information to the extent permitted by applicable law. When we use de-identified information, we maintain and use the information in de-identified form and do not attempt to re-identify it, except to check whether our de-identification processes satisfy the requirements of CCPA.

Retention of California Personal Information. We retain personal information in identifiable form only for as long as necessary to fulfill the purposes for which the personal information was provided to us or, if longer, to comply with legal obligations, to resolve disputes, to enforce agreements, or for other similar, essential purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we process personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements. Once the retention period expires and if not otherwise required to retain information by law, we will delete or de-identify personal information.

Your Rights Regarding Personal Information. California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you; the categories of sources from which we collected personal information about you; our purposes for collecting or selling personal information about you; the categories of personal information about you that we have either sold or disclosed for a business purpose; and the categories of third parties with which we have shared personal information.
The right to request that we delete the personal information we have collected from you.
The right to request correction of inaccurate personal information we maintain about you.
The right to opt out of our sale(s) or sharing of your personal information. Please note that if you opt out of certain processing, we will be unable to provide you with the services that rely on such sales. Note as well that we do not knowingly sell or share personal information of minors under 16 years old.
The right to limit our use or disclosure of sensitive personal information we maintain about you.
The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:

By email at team@trlab.com

Verification Process and Required Information. Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, proof of California residency, your name, and email address.

Authorized Agent. You may designate an authorized agent to make a CCPA request on your behalf by designating such an agent in writing or through a power of attorney. We will require the agent to provide us with proof that you have authorized the agent to make requests on your behalf prior to accepting requests from the agent.

Your Choices

To opt out of our email marketing, you can use the link provided at the bottom of each marketing message. If you opt out of our email marketing, we will still send you messages related to our transactions and relationship with you, such as order confirmations.

For choices with respect to third-party interest-based advertising activities, please see the “Digital Advertising & Analytics” section above.

Updating Your Information

When you have an account with us, you may review, change, or update your information by logging into your account and updating your account settings.

Changes to Our Privacy Policy

If our information practices change, we will post these changes on this page. We encourage you to visit this page periodically to learn of any updates.

Contact

If you have questions, comments, or concerns about this Privacy Policy, please contact us at by email team@trlab.com.