Article 1: Introduction to Privacy Policy

Adventurers of Entre ("we," "us," or "our") recognizes the importance of privacy and is

staunchly committed to safeguarding the privacy and security of your personal data. As a data

controller, we are responsible for how we handle your personal information. This Privacy Policy

is crafted to comply with applicable privacy laws and regulations, including but not limited to the

General Data Protection Regulation (GDPR) for residents of the European Union, the California

Consumer Privacy Act (CCPA) for residents of California, and other relevant data protection

laws that govern the collection, use, and retention of personal information in jurisdictions where

we operate.

This document serves as a formal notification and comprehensive guide outlining the manner in

which your personal data is collected, handled, stored, and protected when you access our

website, engage with our Facebook ads, or use any of our services. It elucidates your privacy

rights under applicable law and delineates our obligations and your entitlements in the context of

data privacy and protection.

By engaging with our services, you acknowledge and consent to the practices described in this

policy. This policy applies to all information collected through our digital platforms and any

related services, sales, marketing, or events.

Article 2: Data Collection, Processing, and Utilization

In our capacity as a data controller, Adventurers of Entre undertakes to collect, process, and

utilize personal data strictly in accordance with applicable data protection laws, such as the

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General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and

other pertinent privacy legislation governing the rights of individuals and obligations of entities

handling personal data.

2.1 Types of Data Collected

To fulfill our contractual obligations, provide enhanced services, and comply with legal

requirements, we collect the following categories of personal data:

● 2.1.1 Personal Identification Information (PII): This encompasses data that can be

used to directly or indirectly identify an individual, including but not limited to, full

names, telephone numbers, and electronic mail addresses. The collection of PII is

predicated on the principle of lawfulness, fairness, and transparency, ensuring that data

subjects are fully aware of the nature, scope, and purpose of the data collection.

● 2.1.2 Financial Data: Includes credit/debit card information and related transactional

data required for processing payments for services rendered or products purchased

through our platform. Collection and processing of Financial Data occur solely based on

the explicit consent of the data subject or as necessary for the performance of a contract

to which the data subject is party.

● 2.1.3 Technical Data: Comprises data collected from the devices and technologies you

utilize to access our services, such as Internet Protocol (IP) addresses, login data, browser

types and versions, time zone settings and locations, browser plug-in types and versions,

operating system and platform. Technical Data is collected for the purpose of ensuring

the optimal performance of our website, enhancing user experience, and for maintaining

the security and integrity of our services.

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2.2 Legal Basis for Processing

● 2.2.1 Consent: For certain types of personal data, particularly Financial Data, we rely on

your explicit consent to process the data. You have the right to withdraw this consent at

any time, without affecting the lawfulness of processing based on consent before its

withdrawal.

● 2.2.2 Contractual Necessity: We process Personal Identification Information and certain

aspects of Financial Data as necessary under the performance of the contractual

agreement between you (the data subject) and us, to provide the requested services.

● 2.2.3 Legitimate Interests: Processing of Technical Data is carried out under the

legitimate interests pursued by us, which include improving our services, ensuring the

security of our digital platforms, and for analytical purposes, provided that such interests

are not overridden by the interests or fundamental rights and freedoms of the data subject.

2.3 Purpose of Data Collection

The collection and processing of personal data are conducted with the specific purpose of:

● Delivering the services and products requested by the user.

● Enhancing the functionality and security of our digital platforms.

● Complying with legal and regulatory obligations.

● Conducting financial transactions and managing user accounts.

● Providing support and resolving any issues related to our services.

2.4 Data Minimization and Retention

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Adventurers of Entre adheres to the principles of data minimization and storage limitation,

ensuring that only the necessary personal data for the specified purposes are processed and

retaining the personal data for no longer than is necessary for the purposes for which the personal

data are processed.

Article 3: Deployment and Management of Cookies and Tracking Mechanisms

In compliance with applicable data protection regulations, including but not limited to the

General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and

other relevant data privacy laws, Adventurers of Entre (hereinafter referred to as "the Company,"

"we," "us," or "our") employs cookies and analogous tracking technologies (collectively,

"Tracking Technologies") to monitor interactions with our service and to store specific

information about the users of our service (hereinafter referred to as "data subjects").

3.1 Nature and Function of Tracking Technologies

● 3.1.1 Definition and Classification: Tracking Technologies refer to cookies, beacons,

tags, scripts, and other similar mechanisms that collect and store information to enhance

and secure the user experience. Cookies are compact files containing a string of

characters sent to your device when you visit a website. These files may carry an

anonymous unique identifier distinct to your device or browser session.

● 3.1.2 Categories of Cookies: The Company utilizes various types of cookies, including

but not limited to:

● Essential Cookies: Necessary for the website's basic functions and to enable

secure, private connections.

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● Performance and Functionality Cookies: Enhance the performance and

functionality of our services but are non-essential to their use.

● Analytics and Customization Cookies: Collect data that is used either in

aggregate form to help us understand how our website is being used or how

effective our marketing campaigns are, or to help us customize our website for

you.

● Advertising Cookies: Used to make advertising messages more relevant to you

and your interests.

3.2 Consent and Control

● 3.2.1 Obtaining Consent: The Company will obtain the data subject's consent for the use

of non-essential cookies in accordance with legal requirements. This consent is captured

through an interactive cookie consent banner that allows data subjects to choose their

preferences regarding the use of cookies on their devices.

● 3.2.2 Withdrawal of Consent and Management of Preferences: Data subjects have the

right to withdraw their consent and modify their cookie preferences at any time through

their browser settings. Most web browsers provide options to notify you when you

receive a cookie or to reject cookies outright. Instructions for blocking or deleting

cookies may vary depending on the device and browser used.

3.3 Implications of Non-Acceptance

Data subjects should be aware that refusing or restricting the use of certain cookies may impact

the functionality and service offerings available on our website. Limitations on cookie usage may

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prevent full interaction with our services, including but not limited to, the inability to log in to

secure areas, complete transactions, or access personalized content.

3.4 Legal Basis for Processing

The processing of personal data through cookies and tracking technologies is based on the data

subject's explicit consent for non-essential cookies, and our legitimate interests for essential

cookies, such as providing a secure environment and improving our services, always ensuring

that such interests do not override the data subjects’ fundamental rights and freedoms.

3.5 Transparency and Data Subject Rights

We commit to maintaining transparency about our use of Tracking Technologies and ensure that

data subjects are fully informed about the collection and use of their personal data. Data subjects

retain their rights under applicable data protection laws, including the right to access, rectify,

and, where applicable, erase personal data processed through cookies and tracking technologies.

Article 4: Objectives and Legal Foundations for the Processing of Personal Data

Adventurers of Entre (hereafter referred to as "the Company," "we," "us," or "our") commits to

processing personal data collected from data subjects (hereafter referred to as "you" or "your") in

strict adherence to applicable data protection legislation, including but not limited to the General

Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other

pertinent privacy regulations. The processing of personal data is undertaken based on the

following lawful grounds and for the purposes delineated herein:

4.1 Lawful Purposes of Data Processing

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● 4.1.1 Provision and Enhancement of Services: We process your personal data to

perform our contractual obligations, provide services you have requested, and enhance

the overall quality and user experience of our services. This includes enabling access to

and use of our services, maintaining and optimizing the functionality of our services, and

deploying new features.

● 4.1.2 Communication and Notifications: Your personal data is used to communicate

with you about updates, changes, or enhancements to our services, including but not

limited to, changes in our terms, conditions, and policies. This processing is necessary for

the performance of a contract to which you are party or to take steps at your request

before entering into such a contract.

● 4.1.3 Interactive Features: We process personal data to facilitate your participation in

interactive features of our services, subject to your consent where required by law. This

may include forums, comments sections, and customer feedback mechanisms.

● 4.1.4 Customer Support: Processing personal data is crucial for offering customer

support services, addressing your queries, and resolving issues related to our services.

This processing activity is carried out to fulfill our contractual obligations and provide

you with the necessary assistance.

● 4.1.5 Analysis and Service Improvement: We utilize personal data for analytical

purposes, to understand how our services are used, identify areas for improvement, and

develop new products and services. This processing is based on our legitimate interest in

enhancing the quality and relevance of our services.

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● 4.1.6 Usage Monitoring: To ensure the security, reliability, and robustness of our

services, we process personal data for monitoring and analyzing the usage of our

services. This includes detecting and preventing unauthorized access or usage, and

ensuring the integrity of our services.

● 4.1.7 Technical Issues Detection and Mitigation: Personal data is processed to detect,

prevent, and address technical issues, bugs, and errors in our services. This is essential for

fulfilling our contractual obligations and ensuring the continuous, secure, and efficient

operation of our services.

4.2 Legal Basis for Processing

The processing of your personal data is founded on several legal bases, including:

● Consent: Where appropriate, we will obtain your explicit consent for the processing of

personal data for specific purposes.

● Contractual Necessity: Where processing is necessary for the performance of a contract

to which you are a party or in order to take steps at your request prior to entering into a

contract.

● Legal Obligation: Where processing is necessary for compliance with a legal obligation

to which we are subject.

● Legitimate Interests: Where processing is necessary for the purposes of the legitimate

interests pursued by us or by a third party, except where such interests are overridden by

your interests or fundamental rights and freedoms.

4.3 Transparency and Your Rights

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We are committed to ensuring transparency in our processing activities and to providing you

with control over your personal data. You have the right to access, correct, delete, or restrict

processing of your personal data, among other rights, under applicable data protection laws.

Article 5: Determination of Lawful Basis for Data Processing Activities

5.1 Contractual Necessity

● 5.1.1 Execution and Management of Contractual Obligations: We process your

personal data as necessary for the performance of contracts to which you are a party, or in

order to take steps at your request prior to entering into a contract. This encompasses

activities required to initiate, maintain, and fulfill the obligations of the contract,

including but not limited to registration, service provision, customer support, and

transaction processing.

5.2 Legitimate Interests

● 5.2.1 Assessment and Balancing Test: Processing based on legitimate interests occurs

only after conducting a thorough assessment to ensure that such interests are not

overridden by your rights and freedoms. Legitimate interests may include, but are not

limited to, direct marketing, fraud prevention, ensuring network and information security,

and the enhancement of our services and communications. The specific legitimate

interests being pursued will be clearly communicated to you at the time of data collection

or processing.

● 5.2.2 Third-Party Interests: In certain instances, we may process your personal data for

the legitimate interests of third parties, provided these interests adhere to the principles of

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data protection and do not infringe upon your rights and interests. Prior explicit

notification will be provided to you, detailing the nature of such interests.

5.3 Legal Obligations

● 5.3.1 Compliance with Applicable Laws: We may process your personal data where it

is necessary for compliance with a legal obligation to which we are subject. This includes

legal mandates, court orders, or regulatory requirements that necessitate the collection,

preservation, or disclosure of personal data within the legal framework applicable to our

operations.

5.4 Consent

● 5.4.1 Explicit Consent: For certain types of personal data processing, particularly those

that do not fall under the categories of contractual necessity, legitimate interests, or legal

obligations, we will obtain your explicit consent. This consent must be a freely given,

specific, informed, and unambiguous indication of your wishes, by which you, through a

statement or a clear affirmative action, signify agreement to the processing of personal

data relating to you.

● 5.4.2 Withdrawal of Consent: You have the right to withdraw your consent at any time

without affecting the lawfulness of processing based on consent before its withdrawal.

The mechanism for withdrawing consent will be as straightforward as the mechanism for

giving consent, ensuring your absolute control over your personal data.

5.5 Special Categories of Personal Data

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● 5.5.1 Enhanced Protections: For processing of special categories of personal data (as

defined under GDPR and other relevant laws), such as data revealing racial or ethnic

origin, political opinions, religious beliefs, or data concerning health, we will rely on

additional legal bases such as explicit consent or the necessity for the purposes of

carrying out the obligations and exercising specific rights of the data controller or the

data subject in the field of employment and social security and social protection law.

Article 6: Framework and Safeguards for the Cross-border Transfer of Personal Data

6.1 Legal Framework for Data Transfers

● 6.1.1 Adequacy Decisions: Where possible, we transfer personal data to countries that

have been deemed to provide an adequate level of data protection by the relevant

regulatory authorities. This ensures that the data is afforded a similar level of protection

as it would be within your jurisdiction.

● 6.1.2 Standard Contractual Clauses (SCCs): In the absence of an adequacy decision,

we rely on approved Standard Contractual Clauses for the transfer of personal data to

third countries. These clauses provide specific data protection safeguards and enforceable

rights for data subjects.

● 6.1.3 Binding Corporate Rules (BCRs): For transfers within our corporate group, we

may use Binding Corporate Rules approved by competent data protection authorities.

BCRs are internal rules that provide a consistent level of protection for personal data

transferred within our corporate group, across borders.

6.2 Safeguards and Security Measures

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● 6.2.1 Implementation of Robust Security Measures: Irrespective of the destination, we

implement appropriate and stringent security measures to protect personal data against

unauthorized access, alteration, disclosure, or destruction. These measures are designed

to ensure the security and confidentiality of the personal data, in line with our

commitment to data protection.

● 6.2.2 Transparency and Data Subject Rights: We remain transparent about the

international transfer of personal data and ensure that data subjects retain their rights in

relation to their data, irrespective of the geographic location of the data processing. This

includes rights to access, rectify, erase, or object to the processing of their personal data.

6.3 Special Circumstances for Data Transfer

● 6.3.1 Derogations for Specific Situations: In limited and exceptional circumstances,

transfers of personal data may be conducted under specific derogations permitted by data

protection laws, such as when the transfer is necessary for the performance of a contract

between the data subject and the controller, or for the establishment, exercise, or defense

of legal claims.

Article 7: Detailed Provisions on Cross-Border Data Processing

7.1 Legal Mechanisms for International Data Transfers

● 7.1.1 Transfer to Countries with Adequacy Decisions: We prioritize transferring

personal data to countries that have been recognized by relevant data protection

authorities as having adequate data protection laws, ensuring an equivalent level of

protection to that offered within your jurisdiction.

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● 7.1.2 Utilization of Standard Contractual Clauses (SCCs): In the absence of an

adequacy decision, we rely on the European Commission-approved Standard Contractual

Clauses as a mechanism to ensure personal data transferred outside the EEA is

adequately protected. These SCCs commit the data recipient to comply with data

protection standards that meet or exceed those within the EEA.

● 7.1.3 Adoption of Binding Corporate Rules (BCRs): For intra-group transfers of

personal data across borders, we may implement BCRs that have been approved by

competent data protection authorities, providing a consistent level of protection for

personal data within our corporate group.

7.2 Ensuring Data Protection in Transfers to the United States

● 7.2.1 Compliance with Privacy Shield Framework: Where applicable, we comply with

the provisions of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy

Shield Framework as set forth by the U.S. Department of Commerce regarding the

collection, use, and retention of personal information transferred from the European

Union, the United Kingdom, and Switzerland to the United States, respectively.

● 7.2.2 Implementation of Supplementary Measures: In light of evolving legal standards

and requirements, we continually assess and, where necessary, implement supplementary

measures alongside the SCCs or BCRs to ensure that data transferred to the U.S. receives

an equivalent level of protection.

7.3 Consent and Rights of Data Subjects

● 7.3.1 Informed Consent for Data Transfer: Your consent to this Privacy Policy,

coupled with your voluntary submission of personal data, constitutes your explicit

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agreement to the international transfer of such data. We ensure that you are fully

informed of the potential risks associated with data transfers to countries without

adequacy decisions or equivalent protections.

● 7.3.2 Withdrawal of Consent: You have the right to withdraw your consent to the

international transfer of your personal data at any time. However, it is important to note

that such withdrawal may affect your ability to use certain features of our services that

require the processing of your data in the United States or other countries.

● 7.3.3 Rights to Access and Control: You retain the right to access, amend, delete, or

object to the processing of your personal data, regardless of the location of data

processing. We commit to facilitating these rights in accordance with applicable data

protection laws.

Article 8: Governance of Third-Party Engagements and Data Disclosure

8.1 Third-Party Links and Products

● 8.1.1 External Links: Our digital platforms may, from time to time, contain links to

external sites, including third-party products or services, which are not operated by us.

These sites operate under their own privacy policies and data protection practices. We

assert that we hold no control over, and assume no responsibility for, the content, privacy

policies, or practices of any third-party sites or services. Users are encouraged to review

the privacy policies of these external sites to understand their data handling practices.

● 8.1.2 User Discretion Advised: The inclusion of third-party links does not imply

endorsement or validation of the content found within. User discretion is advised when

interacting with these links. We remain committed to the integrity of our services and

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welcome user feedback regarding these external sites to assess the compatibility of their

practices with our standards.

8.2 Engagement with Third-Party Service Providers

● 8.2.1 Purpose of Engagement: We engage third-party companies and individuals

("Service Providers") to facilitate certain aspects of our services, provide services on our

behalf, perform service-related functions, or assist in analyzing how our services are

utilized. This includes but is not limited to cloud hosting services, customer relationship

management, and analytics tools.

● 8.2.2 Data Access and Use: These Service Providers may have access to your Personal

Data solely for the purpose of performing these tasks on our behalf under strict

confidentiality agreements. They are contractually bound to not disclose or use the

information for any other purpose.

● 8.2.3 Due Diligence and Compliance Verification: We conduct comprehensive due

diligence and require that our Service Providers adhere to privacy standards that are

compatible with ours and comply with applicable data protection laws. This includes

implementing appropriate technical and organizational measures to ensure the security

and confidentiality of personal data.

● 8.2.4 Accountability and Transparency: We maintain a record of our processing

activities in relation to third-party disclosures and ensure transparency in our engagement

with Service Providers. Users have the right to be informed about the identity of these

third parties and the purposes for which their data is being processed.

Article 9: Compliance with Data Protection Regulations

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9.1 GDPR Compliance for EU Users

9.1.1 Overview of GDPR Rights: If you reside within the European Union, the General Data

Protection Regulation (GDPR) grants you specific rights regarding the processing of your

Personal Data. Adventurers of Entre commits to facilitating these rights in compliance with

GDPR requirements.

● Right to Access: You have the right to request access to your Personal Data, obtain a

copy of your Personal Data held by us, and receive other information about how and on

what basis that data is processed.

● Right to Rectification: You are entitled to correct or update your Personal Data if it is

inaccurate or incomplete.

● Right to Erasure ("Right to be Forgotten"): Under certain circumstances, you can

request the deletion or removal of your Personal Data from our records.

● Right to Restrict Processing: You have rights to 'block' or suppress further use of your

Personal Data under certain conditions.

● Right to Data Portability: You have the rights to receive, in a structured, commonly

used, and machine-readable format, the Personal Data you have provided to us, and to

transmit that data to another data controller.

● Right to Object: You have the right to object to the processing of your Personal Data

based on legitimate interests, direct marketing (including data aggregation), and

processing for statistical purposes.

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● Automated Decision Making and Profiling: You have the right not to be subject to a

decision based solely on automated processing, including profiling, which produces legal

effects concerning you or similarly significantly affects you.

9.1.2 Exercising GDPR Rights: To exercise any of these rights, please contact us using the

contact information provided in our privacy policy. We may need to verify your identity before

implementing your request.

9.2 CCPA Compliance for California Residents

9.2.1 California Privacy Rights: In compliance with the California Consumer Privacy Act

(CCPA) and California's Shine the Light law, California residents are afforded specific rights

regarding their Personal Data.

● Right to Know and Access: You can request disclosure of the categories and specific

pieces of Personal Data we have collected about you.

● Right to Deletion: You have the right to request the deletion of your Personal Data

collected or maintained by us.

● Right to Opt-Out of Sale: You have the right to opt-out of the sale of your Personal

Data to third parties. Adventurers of Entre does not sell personal information, and any

future changes to this practice will be communicated in accordance with CCPA

requirements.

● Right to Non-Discrimination: You have the right not to receive discriminatory

treatment for exercising any of your CCPA rights.

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9.2.2 Exercising CCPA Rights: California residents can exercise these rights by contacting us

with a request. We will verify your request using the information associated with your account,

including email address. Further identification may be required for security.

9.3 Contact Information for Data Rights Requests

For any requests under GDPR or CCPA, or queries regarding your data rights, please contact us

via the designated contact method specified in our privacy policy. We are dedicated to

addressing your concerns and aim to resolve any issues surrounding the processing of your

Personal Data.

Article 10: Jurisdiction and Governing Law

10.1 Jurisdictional Scope and Applicability

Adventurers of Entre ("the Company", "we", "us") operates primarily under the legal jurisdiction

of the United States and, more specifically, within the State of Colorado. This Privacy Policy,

encompassing the collection, use, and disclosure of Personal Data obtained through our services,

is fundamentally governed by and construed in accordance with the laws of the United States and

the State of Colorado.

10.2 Governing Law

● 10.2.1 Primary Legal Framework: The provisions set forth in this Privacy Policy and

any disputes arising from or related to the interpretation, violation, enforceability, or

validity of this Privacy Policy are governed by and construed in accordance with the laws

of the State of Colorado, without giving effect to any choice or conflict of law provisions.

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● 10.2.2 Federal Law Considerations: Where applicable, federal laws of the United States

will also govern the interpretation and enforcement of this Privacy Policy, especially in

matters exceeding the exclusive jurisdiction of the State of Colorado.

10.3 International Considerations

● 10.3.1 Compliance with International Laws: Recognizing the global nature of the

internet and the cross-border transfer of Personal Data, we strive to comply with all

applicable data protection laws and regulations beyond our primary jurisdiction,

including but not limited to the General Data Protection Regulation (GDPR) for residents

of the European Union, and the California Consumer Privacy Act (CCPA) for residents

of California, USA.

● 10.3.2 Adaptation to Local Laws: When our services are accessed by users residing

outside the United States, we endeavor to ensure that our data processing activities

comply with the local laws of the user's jurisdiction, to the extent that these laws provide

additional protection or rights to users beyond those covered by United States and

Colorado law.

Article 11: Contact Information

For any questions or comments about this Privacy Policy, please contact us at:

● Email: geoffreyopper@gmail.com

● Address: Adventurers of Entre, 9878 West Belleview Ave Ste 2706, Denver, CO 80123,

USA