Privacy Policy

Effective date: 14 April 2023

  1. Introduction
  1. In this Privacy Policy, “us”, “we” or “our” means Buzz Development Inc.. This Privacy Policy sets out the details relating to your data relationship with Buzz Development Inc. and its authorised representative (Perion Data Representative) that owns, and is responsible for collecting, storing, processing and transferring, data in respect of our services and your interactions with Buzz Development Inc. (Buzz Development Inc. activities).
  2. The appointment terms, responsibilities and obligations of the Perion Data Representative is subject to change based on the prevailing model of Buzz Development Inc. governance and proposed approved by Buzz Development Inc. governance as it adapts to accommodate emerging laws and clarifications on how existing laws apply to DAOs.
  3. Personal data includes any information relating to an identified or identifiable natural person (Personal Data). By using our services, you consent to the collection, storage, processing, and transfer of your Personal Data under this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes on our website (located at (Website). Please check our website periodically to ensure you understand our current Privacy Policy (Privacy Policy).
  4. The Perion Data Representative is the Data Controller for Personal Data collected in connection with providing our services and your Buzz Development Inc. activities. The Perion Data Representative generally collects your Personal Data directly from where you are based and may store it on servers outside the EU or European Economic Area (EEA) in countries such as Australia or the USA, where data protection standards may be lower than in the EU/EEA.

  1. Personal Data categories
  1. The categories of Personal Data the Perion Data Representative may process depends upon the nature of your dealings with us and may include:
  1. Personal details: name, gender, date of birth, nationality, tax residency;
  2. Contact details: address, email address, mobile number, social media account;
  3. Interaction details: activity details of your interactions with Buzz Development Inc.;
  4. Payment details: payment and transaction information, including type, bank, and credit card details;
  5. Technical information: device ID, device type, geo-location, computer and connection information, statistics on page views, traffic to and from our websites, ad data, IP addresses and web log information;
  6. Blockchain transactions: any bids, offers, buys, sells, transfers (including involving staking and liquidity provision), fees, withdrawals, claims, mints, burns, or other like interactions associated with your IP address and your Ethereum (or other) public address;
  7. Customer support: details of the services we have provided to you or that you have enquired about, including any additional information necessary to deliver those services and respond to your enquiries; and
  8. Feedback: information you provide to us through surveys.

  1. How we collect your Personal Data
  1. We may collect Personal Data about you when you:
  1. Visit our Website;
  2. Visit and interact with our Staking Interface, located at (Staking Interface);
  3. Communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services, Buzz Development Inc. activities, our Website or our Staking Interface;
  4. Make enquiries, report suspicious market activity, bug reports under our Bug Bounty Program located at here, ideas, or other feedback about our services, Website or Interface;
  5. Connect your compatible Ethereum wallet to our Interface, sign or effect a blockchain transaction or otherwise interact with the suite of contracts deployed by Buzz Development Inc. on the Ethereum ledger (and other ledgers from time to time) that form the Buzz Development Inc. Protocols, including the $PERC token contract (Perion Protocols);
  6. Interact with our Website, Interface, other services, Buzz Development Inc. activities, content, advertising, or join our mailing list;
  7. Participate in a competition, promotion, or survey;
  8. Post a review, rating, comment, or other user-generated content on our Website or Staking Interface; and
  9. Submit your resume to us for a job application.
  1. We may also collect Personal Data when we receive your Personal Data from third parties who legally provide it to us. For example, if we receive information about you from any recruitment consultant, your previous employers or principals and others who may be able to help us decide whether to make you an offer or involve you in Buzz Development Inc. activities.

  1. Purposes for using your Personal Data
  1. We may use your Personal Data to:
  1. Enable you to access and use our Website, Staking Interface, Perion Protocols, participate in DAO activities and other services;
  2. Operate, protect, improve and optimise our Website, Staking Interface, Buzz Development Inc. activities, Perion Protocols and services, business and our community participants’ experience, such as to perform analytics, conduct research and for advertising and marketing;
  3. Send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and the information requested by you;
  4. Send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
  5. Administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by our business partners or us;
  6. Comply with our legal obligations, resolve any disputes that we may have with any of our users, enforce our terms and other agreements, or protect the rights, property, or safety of Buzz Development Inc. or others; and
  7. Consider your employment or other application.
  1. The Perion Data Representative may disclose your Personal Data to a trusted third party who holds other information about you. This third party may combine that information to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services you receive.

  1. Lawful basis for processing Personal Data
  1. Subject to applicable law, the Perion Data Representative may rely on one or more legal bases included in the General Data Protection Regulation (GDPR) to process your Personal Data in connection with the purposes set out in this Privacy Policy, including in circumstances where:
  1. We and the Perion Data Representative have obtained your express prior consent to the processing (art 6(1)(a) GDPR);
  2. The processing is necessary to perform our and the Perion Data Representative’s contractual obligations to you (Art. 6(1)(b) GDPR);
  3. The processing is required by applicable law (art 6(1)(c) GDPR);
  4. The processing is necessary to protect the vital interests of any individual (art 6(1)(d) GDPR);
  5. We and the Perion Data Representative have a legitimate interest in carrying out the processing to manage, operate, or promote our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms (art 6(1)(f) GDPR); or
  6. When the Perion Data Representative involves third-party processors in the performance of our services and contractual obligations, and such involvement requires the sharing of Personal Data, the Perion Data Representative has entered into data processing agreements with our third-party processors according to art 28 GDPR and, if required, further appropriate safeguards according to art 46 – 49 GDPR.

  1. Special categories of Personal Data
  1. Subject to applicable law, we or the Perion Data Representative does not seek to collect or process your Sensitive Personal Data (as defined in the GDPR and as amended from time to time), except where:
  1. The processing is required or permitted by applicable law;
  2. The processing is necessary for the establishment, exercise, or defence of legal rights; or
  3. We or the Perion Data Representative has obtained, under applicable law, your express consent before processing your Sensitive Personal Data.

  1. Disclosure of Personal Data
  1. The Perion Data Representative may disclose Personal Data for the purposes described in this Privacy Policy to:
  1. Any employees and related bodies corporate of Buzz Development Inc. or the Perion Data Representative;
  2. Third-party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our services and Buzz Development Inc. activities to you);
  3. Professional advisers, dealers and agents;
  4. Our existing or potential agents, business partners or partners;
  5. Our sponsors or promoters of any competition that we conduct via our services and Buzz Development Inc. activities;
  6. Anyone to whom our assets or businesses (or any part of them) are transferred;
  7. Specific third parties authorised by you to receive information held by the Perion Data Representative; and
  8. Other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

  1. International transfer of Personal Data
  1. The Perion Data Representative may transfer your Personal Data to third-party suppliers and cloud providers outside the EU/EEA in countries such as Australia or the USA. The Perion Data Representative is responsible for putting in place suitable technical, organisational, and contractual safeguards to ensure that any transfer is carried out in compliance with applicable data protection rules, except where the country to which the data is transferred has already been determined by the European Commission to provide an adequate level of protection.

  1. Security
  1. The Perion Data Representative may hold your Personal Data in either electronic or hard copy form. We and the Perion Data Representative take reasonable steps to protect your Personal Data from misuse, interference, and loss, as well as unauthorised access, modification, or disclosure. We and the Perion Data Representative use a combination of physical, administrative, personnel and technical measures (such as encryption protocols and software) to protect your Personal Data.

  1. Direct marketing
  1. We, the Perion Data Representative and/or our carefully selected business partners may send you direct marketing communications and information about our services. This may take the form of emails, SMS, mail, or other forms of communication. You may opt-out of receiving marketing materials by contacting us using the details below or the opt-out facilities provided (e.g., an unsubscribe link).

  1. Your data protection rights
  1. Subject to applicable law, you are entitled to the following data protection rights:
  1. Right to access: you have the right to obtain confirmation that your Personal Data is processed and obtain a copy of it as well as specific information related to its processing;
  2. Right to rectify: you can request the rectification of Personal Data that is inaccurate or add to it;
  3. Right to delete: you can, in some cases, have your Personal Data deleted;
  4. Right to object: you can object, for reasons relating to your circumstances, to the processing of your Personal Data;
  5. Right to limit the processing: in certain circumstances, you have the right to limit the processing of your Personal Data;
  6. Right to portability: you can request to receive your Personal Data in a structured, commonly used, and machine-readable format, or, when this is possible, that we communicate your Personal Data on your behalf directly to another data controller;
  7. Right to withdraw your consent: for processing requiring your consent, you have the right to withdraw your consent at any time; however, exercising this right does not affect the lawfulness of any processing based on your prior consent;
  8. Right to set instructions relating to the use of your Personal Data post mortem: you have the right to define instructions relating to the retention, deletion, and communication of your Personal Data after your death;
  9. Right to complain to the relevant data protection authority.
  1. If you have any questions or objections about how we and the Perion Data Representative collect and process your Personal Data, or if you would like to exercise any of the above rights, please contact us using the information below.

  1. Data retention
  1. The Perion Data Representative may hold your Personal Data for as long as it is reasonably necessary to enable you to access and use our services and participate in Buzz Development Inc. activities. The Perion Data Representative may retain your Personal Data wholly or partly for a longer or shorter period under applicable laws or any other lawful reason. The Perion Data Representative data retention periods may be altered from time to time based on regulatory or other changes.

  1. Cookies
  1. The Perion Data Representative may use cookies and similar tools to enhance your user experience, provide our services and Buzz Development Inc. activities, and understand how the Buzz Development Inc. community use our services and interact with Buzz Development Inc. activities so we can make improvements. Cookies are small amounts of information that are stored on your devices. Cookies enable the Perion Data Representative to recognise you across different websites, services, Buzz Development Inc. activities, devices and browsing sessions. You can disable cookie installation via your browser settings.

  1. Use of third-party software
  1. All blockchain transactions in relation to the Perion Protocols are facilitated and run through your compatible Ethereum wallet (e.g., MetaMask), which allows you to interact with public blockchains and applications deployed on a public blockchain. MetaMask is a third-party electronic wallet extension (Third Party Extension).
  2. By using a Third Party Extension to access the Perion Protocols, you agree that you are governed by the terms of service and privacy policy for the applicable Third Party Extension. For example, the MetaMask Terms of Service and Privacy Policy are available at ( and ( respectively but may be updated from time to time. In connecting your compatible Ethereum wallet to access the Perion Protocols and signing or effecting transactions, each blockchain transaction is passed on to the Third Party Extension, which completes the transaction on your behalf.
  1. Links
  1. Our Website and Staking Interface may contain links to websites operated by third parties. These links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites. We have no control over, or rights associated with any linked websites. The privacy policies that apply to linked websites may differ substantially from our Privacy Policy, so we encourage you to read them before using them.

  1. Making a complaint
  1. If you have any concerns about how we or the Perion Data Representative have handled your Personal Data, you can contact the Perion Data Representative using the details below. Please include your name, email address and/or mobile number and clearly describe your complaint. The Perion Data Representative will acknowledge your complaint and respond to you within a reasonable period. If you think that the Perion Data Representative has failed to resolve the complaint satisfactorily, we will provide you with information about further steps you can take. You also have the right to contact your local data protection authority.

  1. Contact Us, Data Controller
  1. For any questions or requests, please contact us as at [email protected].