Privacy Policy
LAST UPDATED: March 2025
This Privacy Policy explains how Ex Populus, Inc. and its subsidiaries and affiliated companies (“Ex Populus,” “we,” or “us”) collects, uses, and discloses information about you. This Privacy Policy applies when you use our websites, platforms, Products, and services that are linked to this policy (our “Service”), engage with us on social media, or otherwise interact with us. Ex Populus is the company that oversees the development and operation of a number of video games, blockchain projects, and emerging technologies, including but not limited to Ex Populus Digital Collectibles Store and Gaming Platform (the “Collectibles Store”) and Raijin Play Rewards Platform on raijin.gg (“Raijin”) (each a “Product”).
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you. If you do not agree to this Privacy Policy, you may not access or use our Services.
Special Note Regarding Children Under the Age of 13
Our Service is not intended for children under 13 years old. No one under age 13 may provide any personal information to or on the Service. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Service or through any of its features, register for an account, make any purchases, use any of the interactive features, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected]. Certain Services will only be available to people who are 18 years of age or older.
Table of Contents
Sharing of Information
Your Choices
Contact Information
Collection Of Information
Information You Provide to Us
We collect information you provide directly to us. For example, you share information directly with us when you create an account, sign up for marketing updates, or otherwise communicate with us. The types of personal information we may collect include your name, email address, phone number, username, social media profile, other identifier by which you may be contacted online or offline, and any other information you choose to provide, including content from your communications to us.
When making a purchase using the Collectibles Store, we collect payment information to process the transaction and will collect your public digital wallet address.
When you interact with Raijin, you will be asked to provide your email address, and connect your Steam account, which will in turn provide us with your Steam ID and Steam User Name via Steam’s third party API. This will allow you to track in-game achievements and follow leaderboards on Raijin. If you opt-in to participate in redemptions and rewards, we will collect additional personal information from you in order to verify your identity, location, and to confirm compliance with applicable laws. Please see Section 4 of our Terms of Service regarding “Know Your Customer” protocols.
Information We Collect Automatically When You Interact with Us
When you access or use our Service or otherwise interact with us, we, or our Service Providers (defined below) automatically collect certain information that includes:
Device and Usage Information: We collect information about how you access our Service, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, user agent, and browser type. We also collect information about your activity on our Service, such as search queries, access times, pages viewed, links clicked, and the page you visited before navigating to our Service.
Information Collected by Cookies and Similar Tracking Technologies: We (and our Service Providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Service and your experience, see which areas and features of our Service are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Service and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see the Your Choices section below.
IP Geolocation and Fraud Detection: We (and our Service Providers) collect your IP geolocation, ISP, Longitude / Latitude of POP, as well as other IP data. We may anonymize or aggregate certain data for analytics purposes, especially in cases of fraud detection.
Transactional Information: When you make a purchase, we collect information about the transaction, such as product details, purchase price, and the date of the transaction.
Information We Collect from Other Sources
We obtain information from third-party sources. For example, we may collect information about you from Social Networks, Ad Networks, SSPs, DSPs, DMPs, DFPs and other ad and data related partners.
In addition, when you link your Raijin account to other platforms, such as Steam and/or others, we will collect information including games in your Steam library, game data, achievement data for each game, and gameplay time.
Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer that you are on a specific device based on your user agent.
Behavioral Tracking
We may use the tools described above to collect information about your online activities over time and across our Service and third-party websites. This is known as behavioral tracking. We do not share or sell your personal information to third parties for their purposes, such as targeted advertising. But, we may make suggestions to you on certain games, promotions, products or services we believe would interest you based upon your online behavior. If you would like to opt out of this behavioral tracking, and otherwise delete your account, please see below under Your Choices.
Use Of Information
We use the information we collect to provide our Service and administer your account. We also use the information in the following ways:
Advertising (either personalized advertising on other sites or on the Raijin or Ex Populus websites), Contests, sweepstakes, promotions, or similar Loyalty / points program;
Provide, maintain, and improve our Products and Services;
Process transactions and send you related information, including confirmations, receipts, invoices, and customer experience surveys;
Personalize and improve your experience of our Service;
Send you technical notices, security alerts, and support and administrative messages;
Respond to your comments and questions and provide customer service;
Communicate with you about Products, Services, and events offered by Ex Populus and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
Monitor and analyze trends, usage, and activities in connection with our Service;
Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Ex Populus and others;
Debug to identify and repair errors in our Service;
Comply with our legal and financial obligations; and
Carry out any other purpose described to you at the time the information was collected.
We may also use your information to contact you about our own and third-parties' products and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, please see below under Your Choices.
Sharing Of Information
We are committed to protecting your privacy and do not sell your personal information to any third parties.
We share personal information as well as non-personally identifiable information (non-PII) in the following circumstances or as otherwise described in this privacy policy:
    We share non-PII with vendors, service providers, and consultants that need access to personal information in order to perform services for us (“Service Providers”). Our Service Providers include analytics companies, payment processors, internet cookie information recipients (like Google), IP geolocation, companies that assist us with web hosting, fraud prevention, customer service, and marketing. To the extent we are ever required to share personal information with Service Providers for business purposes, these Service Providers are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
    We may share non-PII with our advertising partners for the purpose of verifying the validity and authenticity of ad campaigns. This information may also be used to assist in invoicing and tracking the effectiveness of advertising efforts. By using Raijin, you consent to the sharing of non-PII with our advertisers in this manner.
    We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law, government agencies, or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
    We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Ex Populus, our users, the public, or others.
    We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
    We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
    Personal information is shared between and among Ex Populus and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
    We share personal information with your consent or at your direction.
We also share aggregated or de-identified information that cannot reasonably be used to identify you.
Analytics
We allow others to provide analytics services on our behalf across the web. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Service, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by Ex Populus and others to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.
Transfer of Information to the United States and Other Countries
Ex Populus is headquartered in the United States, and we have operations and service providers in the United States and other countries. Please note that we and our Service Providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will ensure that transfers of personal information to any country or organization are subject to appropriate safeguards. Additionally, without limitation and where applicable, when transferring personal information from the European Union, we may use standard contractual clauses approved by the European Commission or otherwise in accordance with European protection laws for ensuring adequate safeguards.
Your Choices
Account Information
You may update and correct certain personal information associated with a certain Product at any time by emailing us at [email protected]. If you wish to opt-out of data collection and otherwise delete your account, please email us [email protected] instructing us to do so, but note that we may retain certain information as required by law or for our legitimate business purposes. Note also that we cannot delete your personal information except by also deleting your account. We may not accommodate a request to change information if we believe that the change would violate any law or legal requirement or cause information to be incorrect.
Cookies
Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Service.
Communications Preferences
You may opt out of receiving text messages or promotional emails from Ex Populus by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
State Law Rights
State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:
Confirm whether we process their personal information.
Access and delete certain personal information.
Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.
Transfer their information in a portable format.
Opt-out of personal data processing for:
targeted advertising;
sales; or
profiling in furtherance of decisions that produce legal or similarly significant effects.
Either limit (opt-out of) or require consent to process sensitive personal data.
The exact scope of these rights may vary by state. To exercise any of these rights please either follow the steps above under Your Choices or email us [email protected] using the subject heading: “Consumer Rights Request.” To appeal a decision regarding a consumer rights request email us as the same email address using the subject heading: “Consumer Rights Appeal.”
We will not discriminate against you (e.g., through denying Products and Services or providing a different level of quality of service) for exercising any of the rights afforded to you.
We may require that you provide information to verify your identity before carrying out a request. If you would like to use an agent authorized in accordance with applicable law to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to exercise those rights on your behalf.
Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to [email protected]. However, please know we do not currently sell data triggering that statute's opt-out requirements.
California’s Shine the Light law (Cal. Civ. Code § 1798.83) permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at [email protected].
Additional Disclosures for Individuals in Europe and the U.K.
If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.
Legal Basis for Processing
When we process your personal data, we will do so in reliance on the following lawful bases:
    To perform our responsibilities under our contract with you (e.g., providing the Products and Services you requested).
    When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our Products and Services, conduct data analytics, and communicate with you).
    To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
    When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing of your personal data, you may withdraw such consent at any time.
Data Subject Requests
Subject to certain limitations, you have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, email us at [email protected].
Questions or Complaints
If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:
For individuals in the UK: https://ico.org.uk/global/contact-us/
Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Service. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in our Service.
Contact Information
To ask questions or comment about this privacy policy and our privacy practices, or to request data deletion, contact us at: [email protected].