Privacy Policy.


This Privacy Policy describes how Gami Teknoloji Inc. (herein referred to as "Gami" and "We") collects, processes, shares, transfers, and protects the information You provide on ("Website"). This Privacy Policy constitutes a part of the Terms and Conditions of the Website ("Terms").

The personal information described in this Privacy Policy means data used to identify or contact a single person, which is regulated under the General Data Protection Regulation (“GDPR” or "Law"). We respect and value your privacy as well as the integrity of the information You have provided and/or permitted Us to collect. Thus, We endeavor to follow industry standards to ensure the security and confidentiality of your Personal Information when You use Our Services or access Gami Platform.

By accessing, connecting, clicking on, using, or engaging in Our Services, You indicate and confirm that You have consented and agreed to the terms of this Privacy Policy. You do not have to provide us with the personal data requested from you as per the Law, but if you choose not to, we may not be able to offer you our products or services. We are committed to protecting your personal data and taking all necessary steps to ensure that it is processed only in accordance with your requests.

This Privacy Policy will inform You about the following matters among several others:
Collected Personal Information and Data Subject
How We collect Personal Information
How We use Personal Information
How We protect Personal Information
How long We retain Personal Information
Sharing your Personal Information
Third-Party Collection of Personal Information
Designated Countries and Your Legal Rights
Cross-Border Transfer of Personal Information
Updates or amendments to the Privacy Policy
How to contact Gami

Collected Personal Information and Data Subject

Gami has the relationship with individuals on its Services as described below:
"User" is an individual providing personal information to Us via Our Website, social media accounts, or other means. Hereinafter, We may refer to User as "You" in this Privacy Policy.

The following are the types of information We collect, store, and process when You use Our services:
Information provided by You when connecting with Gami and for KYC purpose
Prior to connecting or participating in Gami Platform to use Our Services, You must provide Us with your full name, birthday date, nationality, location, government identification number (Identification Card/Passport Number and Date of the Issuance of Identification Card/Passport), digital wallet address, email address, IP address, your photo and other information as We required which can be used to distinguish your identity, to access the Gami Platform and for the Know Your Customer ("KYC") Verification purpose. Additionally, You will use single sign by logging in to Our Services using Metamask. These services will authenticate your identity and provide You the option to share certain information with Us such as your username and email address.

Categories of the collected Personal Information are as follows:

Usage Information

When You engage or use Our Services, We will monitor your information in relation to your usage of Gami Services 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 either be directly obtained by Gami or through third party service providers.

We collect this type of information to ensure that Our interface and/or Platform is seamlessly accessible for all users around the world, except users in the prohibited jurisdictions.

Communication Information

You hereby agree that We are entitled to collect and use or process the Personal Information You have provided on Our Platform or generated through your usage of Gami Services for the purpose of being able to communicate with You through messages, requests, emails, live chats, file attachments in connection with your transactions on Gami, or any other information related to your contact with Gami.

Financial Information

You hereby agree that, 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. This includes, without limitation, your transaction history such as your initial cryptocurrency or token amount, your Gami Token amount, your staking instructions, your wallet address etc.

We collect this financial information to monitor suspicious financial activities to protect You from fraud, resolution of legal cases, as well as any other purposes disclosed in this Privacy Policy.

How We collect Personal Information

Information automatically collected by Us
We will collect and process Personal Information automatically provided by You under the following situations:
when You visit and/or firstly connect with the Website;
when You voluntarily complete any user survey or provide feedback to Us via emails or any other electronic channels;
when You use browser cookies or any other relevant software upon visiting the Website; or other situations where We may automatically collect your information as described in this Privacy Policy, Our Terms, or other relevant agreements with You.
Information collected by the third-party We will collect your Personal Information from the third parties as required or permitted to the extent of applicable laws. Information from the third-party sources will include, but will not limited to, public databases, ID verification partners, KYC Verification partners, blockchain data, marketing partners and resellers, advertising partners, and analytics providers.

How We use Personal Information

Your Personal Information will be made available to need-to-know basis to Gami, Our Affiliate, Our Partners and/or within Our group of companies. This will include, but not be limited to, the employees and/or any persons or third parties working for Gami who 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 primarily use your Personal information, either collected or delivered, in order to enable your use of Gami Services (including, but not limited to, processing transactions), to improve the efficiency of the Services, the process to participate in the IDO fundraising project event, 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 to detect suspicious activities and to protect against automated abuse such as spam, phishing, and 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 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 fulfil the purpose of public interest, or to pursue Our reasonable interests), We may use and process your Personal Information without obtaining your consent.

For communication purposes

We use your Personal Information, collected or derived from your communication devices or your email address, to interact with You directly, to provide You with necessary support, and/or to keep You informed of wallets connected, transactions, staking instructions, security details, as well as other aspects. All direct communications will be appropriately maintained at Gami, or the service providers designated by Gami, 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 Terms.

To enforce Our Terms, and other relevant agreements

Personal Information is also used to enforce Our Terms continuously and actively among, and other agreements relating to the Services on Gami Platform. Activities in this regard include, but are not limited to, reviewing, processing, verifying, investigating, mitigating and preventing any potentially prohibited or illegal activities that may violate preceding provisions, or disclose relevant information to third parties in accordance therewith. In light of this, Gami shall be entitled to freeze/close/delete accounts or any User activity on the Website as necessary to any User found to be engaged in any activities that violate Our Terms and other relevant agreements.

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 Affiliate, Our Partners and/or Our group of companies) and your interests and fundamental rights do not override those interests.

How We protect Personal Information

Gami undertakes to take all necessary technical and administrative measures and to show the necessary care to ensure the security of your personal information. Gami takes the necessary measures to prevent unauthorized access, misuse, illegal processing, disclosure, alteration or destruction of personal information. Gami uses generally accepted security technology standards such as firewalls and encryption when processing personal information. Regarding the prevention of unlawful access to the personal information processed by Gami, the prevention of unlawful processing of these data and the protection of personal information:

The website where personal information is taken protects all domains with SSL, Creates and applies access authorization and control matrices for its employees, It ensures that personal data in paper environment are kept in lockers and accessed only by authorized persons. Although Gami takes the necessary information security measures, in the event that personal data is damaged or obtained by unauthorized third parties as a result of attacks on platforms operated by Gami or the Gami system, Gami immediately notifies the data subjects.

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 Us for KYC Verification while You have been using or accessing Gami Platform and the Services, and after your use of the Services for a reasonable period of 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 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 Gami.

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 to 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, or We may disclose Personal Information to third parties that provide supporting services, or analytical information for the purpose of 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 that You provide to Us during the initial connecting process is passed to these services at KYC Verification process and on an ongoing basis thereafter.

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

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

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 the use of 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. 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 information that is collected. It may be in your interest to individually restrict or enable such data collections.

Designated Countries Privacy Right and Your Legal Rights

This provision applies to Users of the Services that are located in the EEA, United Kingdom and/or Switzerland (herein collectively referred as "Designated Countries") at the time of Data or Personal Information being collected. We may ask your information regarding your nationality, your location, which 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 obfuscates location information so as 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 as "Data Protection Laws"). The lawful basis for processing your Personal Information includes (i) your consent, (ii) performance of a contract, (iii) a legitimate interest, (iv) a compliance with legal obligations, (v) protection your vital interest, and (vi) public task.

In the event of any conflict or inconsistency between any term in this provision and other terms contained in this Privacy Policy, the term in this provision will govern and control over Users in the Designated Countries.

Under certain circumstances when You use Our Services, You have the rights under the Data Protection Laws in relation to your Personal Information. These rights include the followings:

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 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 records where (i) your Personal Information is no longer necessary to be used for the Services or on the Platform, (ii) Personal Information was collected in relation to processing that You previously consented to, but later withdrew such consent, or (iii) 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 fulfil 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 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 contests 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.

RRight to withdraw consent ("Opt-out")

You reserve the right to withdraw your consent at any time where 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 the Website or send a request to the e-mail address stated in “How to contact Gami” section.

Please also be noted that there are some limitations when You wish to exercise any one of these individual rights. We may limit your individual rights in the following situations:

(i) Where denial of access is required by laws;
(ii) When granting access would have a negative impact on others' privacy;
(iii) In order to protect Our rights and properties;
(iv) Where the request burdensome.

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 to be processed outside of the country where You are located or outside the Designated Countries, it is not suggestible if your Personal Information is restrictive.

However, if You wish to continue using Our Services outside the Designated Countries and your home locations, We will ensure that We will transfer your Personal Information only to country that has the required contractual provisions for transferring Personal Information in place with the third parties to which your Information is transferred, or to country where is approved by the EU authorities as providing an adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection in the jurisdiction of the party receiving the information. In this manner, You hereby expressly consent to this transfer, and agree that We will not be responsible for any additional Terms, policies or any other guidelines implemented by any party receiving the information.


Our Services are not designed for the individuals who are under the age of 18 or under the legal age to provide consent under the applicable laws of country or jurisdiction where You are using Our Services or Platform. If You are not over 18 or of the legal age of your country, You will not provide any Personal Information to Us, or to 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 then discard such information and block your access to Gami Platform 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.

Updates or amendments to the Privacy Policy

We may periodically review this Privacy Policy. The most current version of the Privacy Policy will determine how your personal data is used and will be available on this page. If you continue to access or use the site and the application after these changes become effective, you agree that you are bound by this revised Privacy Policy.

How to contact Gami

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, please submit your requests to [email protected] and visit Our Website.