Privacy policy

Last modified date 11/22/2022
Thank you for choosing our platform and services.

In order to use the MULTI FACE DAO Platform, the website and the services thereon (together, the Platform, the Site and the services hereinafter referred to as the "Platform"), and to further improve them, the Platform (" MULTI FACE DAO ", "we", "us", or "our") collects information from you.

This Privacy Policy explains how the Platform collects, stores, uses, transfers and discloses your information.

From time-to-time MULTI FACE DAO may revise this Privacy Policy. We will give you notice by posting the revised Privacy Policy on our Platform and updating the "Last Updated and Effective" date at the top of this Privacy Policy; we also offer to notify you in other ways, such as using the contact information provided to you or using restricted access on our Platform. Any changes to this Privacy Policy will become effective immediately upon the posting of the updated Privacy Policy, unless otherwise specified or required by applicable circumstances (for example, a different form of terms and conditions for granting consent or refusal, etc.). By continuing to use our Platform, you agree to the updated Privacy Policy to the fullest extent permitted by applicable law.

You should read this Policy in its entirety but here are a few key points:
When you use our Platform, even if you are just browsing it, we collect information from you such as the type of device you are using and your IP address.

You may share additional information with us such as your email address by creating a personal account or performing other actions available on the Platform.

If you have questions about this Policy how we collect or process your personal data or anything else related to our privacy practices we would love to hear from you - see Contact Us.


1.1. This Privacy Policy applies to all aspects of our Platform as well as to information we may collect offline.
1.2. This Platform may link to or include websites or content hosted and served by others over which we have no control, such as third parties’ websites, online resources, platforms, social networks or systems, which are each governed by the privacy policy and business practices of the third party. You understand and agree that PiePack is not responsible for the security, privacy, or business practices of any third party.
1.3. Terms Used
Personal data is any information relating to an identified natural person, such as name, identification number, location data, online identifier, or one or more factors specific to your physical, economic, cultural or social identity as an individual.


2.1. We collect information from you directly, automatically when you visit the Platform, and sometimes from third parties. Some of this information may be considered as "personal information" under various applicable laws.
2.2. We consider information that identifies you as a specific and identified individual to be personal information (such as your name, telephone number, and email address), as well as additional information, including IP addresses and cookie identifiers, where required by applicable law. And, if we combine information that we consider to be non-personal with personal information, we will treat the combined information as personal information under this Privacy Policy. Note that we may de-identify personal information so that it is non-personal, such as by aggregating it or converting it to a code, sometimes using a function known as a "hash." We will treat de-identified information as non-personal to the fullest extent permitted by applicable law.
2.3. We may collect the below information:
Individual clients:
• Email address;
• Cell phone number;
• Full legal name (including former name and names in local language(s);
• Nationality;
• Passport number or any identification number issued by the government;
• Date of birth ("DOB"),
• Proof of identity (such as a passport, driver's license, or government-issued ID);
• Address of residence;
• Proof of residency;
• Additional personal data or documentation at the discretion of our compliance team.
Corporate clients:
• Legal name of the company (including the official name in the local language);
• Incorporation/registration information;
• Full legal name of all beneficial owners, managers and legal representatives;
• Address (principal place of business and/or other physical location);
• Proof of good standing;
• Description of the business;
• Percentage of ownership for individual/corporate owners;
• Contact information of owners, managers and executive management (if applicable);
• Proof of identity (such as a passport, driver's license or government-issued ID) of the significant individual beneficial owner of the client’s entity;
• Personal Data of the significant beneficial owner of each client’s entity (for details on what Personal Data we collect about individuals, see the Individual Client section above);
• Source of wealth;
• Number of bitcoins or other digital assets expected to be introduced.
2.4. Legal grounds to collect Personal Data
Execution of a contract when we provide you with products or services. This includes using your personal information to receive and process orders and payments.
Legal obligation. To comply with our legal obligations under applicable laws and regulations and anti-money laundering laws and regulations.
Your consent. When we ask for your consent to process your personal information for a specific purpose, we communicate to you.
When you consent to the processing of your personal information for a specific purpose, you may withdraw your consent at any time and we will stop processing your personal information for that purpose. Withdrawal of consent does not affect the lawfulness of processing based on consent prior to its withdrawal.


MULTI FACE DAO may collect personal information from you when you:
Create an account, log in to or interact with the Platform.
MULTI FACE DAO collects your name and email address as well as other information you provide, such as your phone number when you register or log in, update or add information to your account. We require that you create a username and password if you create an account although we may enable other methods such as through your Apple ID and WalletConnect.
MULTI FACE DAO also collects certain information related to any social media platform account or Apple ID that you use to log in to or link to your MULTI FACE DAO account (such as your username, bio, and number of followers) notwithstanding linking any such account to your MULTI FACE DAO account, logging into MULTI FACE DAO through such account is entirely up to you. We may store data about your crypto wallet without the ability to access it from our side, but only if you choose to store it in your account.
Interaction via Platform
(i) MULTI FACE DAO serves as a WEB3 platform to facilitate the payment for the services of companies and individual experts, increase the transparency of operations and, as a result, increase trust between Participants and their income. The functionality of the Platform ensures independence from problems related to payments for services in fiat, including blocking payments, sanctions, freezing accounts, etc. These opportunities and changes facilitate collaboration between people and companies interested in working on the Platform, but located in different jurisdictions.
(ii) Interaction on the Platform is carried out via smart contracts, which are autonomous technological entities stored in the decentralized Blockchain network, which guarantees the non-interference of third parties (including the Platform) in a predetermined fundraising algorithm and ensures the reliability of the transaction and also means that the interaction process is carried out without our intervention on the conditions predetermined in the smart contract.
The Platform itself does not gain access to the management and contents of your crypto wallets.
Providing information about Users and their goods/services/works on the Platform
We collect information when you send us content such as a video, description, photo, email, text or other message (each a "Submission"). All information posted on the Platform is subject to the Terms of Service. As a result, others can access, use and share it in accordance with the Terms of Service.

The Platform collects information.

When you use our Platform, depending on your role, we collect, in addition to the information provided when you created your account, your name, email address, phone number and social media usernames that you provide, videos and other the information you uploaded.
For operation of smart contracts, the Platform collects information necessary to provide you with access to all the features of the Platform. But the Platform does not have access to your wallet or any transactions with it.
We and our third-party business partners may collect information about your visits to and activities on our Platform or websites and services. We may combine this information with other personal information we have collected from or about you. We may share certain information with third party business partners for similar purposes.


When you visit our Platform or otherwise interact with us or our content, we, third-parties advertising and analytics companies, and other third-party business partners may use various tracking and other technologies that automatically or passively collect certain information (“Usage Information”).
We may use these technologies for a number of reasons, including to store your preferences for future visits to our Platform, to retain your authorization between visits, to provide you with targeted advertising and to provide you with improved services. The information we collect may include (but is not limited to):
date and time of your visit to our Platform;
sections you visit within our Platform;
links you click on within our Platform;
websites or advertisements you visit before or after visiting our Platform;
terms you entered into a search engine that lead you to our Platform;
IP address, mobile device identifier, or other unique identifier and usage information for the device used to access our Platform;
precise location data from your device, if you have opted-in to the collection of that information (you may be able to disable the collection of precise location data through the settings on the device used to access our Platform, but your approximate location may remain available through its IP address or other information that we collect)
device and connection information, such as browser type and version, operating system, and platform; and
whether an email message we sent was opened and whether a link in the email message was clicked.
The methods that may be used to collect Usage Information include the following:
A cookie is a data file placed on a device when it is used to visit the Platform or otherwise access to our content. Cookies, flash cookies and other local storage devices may be used for a variety of purposes (for example, to identify your device when you revisit our Platform, to revoke your authentication information, to store information related to your navigation on our Platform or to enable certain features). Some cookies are necessary for the operation of the Platform, and without them, some features and services that you have requested may not be provided. If you disable cookies, adjust the privacy settings on your device, limit local storage, or otherwise restrict these technologies, you may not be able to use some of the features of our Platform.
Web Beacons
Small graphic images or other web programming code called web beacons (also known as "pixels", "1x1 GIFs" or "clear GIFs") may be included in our web pages and email messages. Web beacons may not be visible to you. Web beacons or similar technologies may be used for a number of purposes, including to count visitors to the Platform, to monitor how users navigate the Platform, to count how many email messages we sent were opened, and to count whether a link in an email message we sent was clicked.
Embedded Scripts
An embedded script is a program code designed to collect information about your interaction with the Platform, such as the links you click. The code is temporarily downloaded to your device from our server or a third-party service provider, active only while you are connected to the Platform, and deactivated or deleted after you are no longer connected.
Other Technologies
We may also use other technologies that collect similar information for security and fraud detection purposes.


We may combine the information we collect from you with information from other sources to manage, tailor content, personalize, customize and improve our Platform. We use your information:
to fulfill your request on the Platform or other offer, or to operate the Platform's smart contracts, deliver email messages and process the information you provide via our Platform;
to maintain your account, to help you access crypto transactions, to facilitate your use of the Platform, and to communicate with you about your account, our relationship with you, and your use of the Platform, such as by verifying your information, requesting your response to polling or checking the status of a request. We may send you text messages if you have provided us with your mobile phone number for this purpose;
to establish and manage a relationship with you depending on your Role on the Platform;
to send you promotional emails or text messages from MULTI FACE DAO (and not from any third party) if you have consented to receive them. To stop receiving email messages, click on the "Unsubscribe" link in the footer of the promotional email; please note that even if you unsubscribed, we may send you communications regarding your account or use of the Platform, such as administrative and service announcements;
to provide you and others with service requests, help resolve problems, and evaluate and improve our customer service and processes;
use any information provided as set forth in the applicable Terms of Service, which may include the public display of some information such as your name, username, or where you live;
to contact you regarding administrative matters, such as the applicable Terms of Service, or other matters;
to understand better your personal preferences and enable us to provide you with improved and personalized communications, services and experiences and offers both from us and those placed by Sellers on the Platform;
to collect summary data about the traffic and interaction of the Platform;
to tailor the content and advertising we show you or others on our Platform or elsewhere, and to analyze trends and statistics;
to create advertising models using twin modeling or other research methodologies;
for internal business purposes, such as improving our Platform, products and services, and to comply with legal requirements and our business practices, such as our record keeping, backup, and document retention policies;
and for other reasons that (a) we disclose when we ask you to provide your information, (b) with your consent, or (c) as described in this Privacy Policy.


We share non-personal information, such as aggregated statistical data and de-identified information, with third parties to the extent permitted by applicable law. MULTI FACE DAO also shares personal information as detailed below. We do not share personal information with any third party for their own marketing or promotional purposes without your consent.
We may share your Personal Data with third parties:
• If we believe that the transfer of personal data is necessary to enforce the Terms of Service;
• If it complies with the requirements of government authorities, including regulatory authorities, law enforcement agencies and / or justice authorities;
• If those third parties provide MULTI FACE DAO services (for example, administrative or technical services);
• In connection with the sale or transfer of our business or any part of it.
In addition, we regularly implement state-of-the-art international standards for preventing money laundering, terrorist financing and circumventing trade and economic sanctions, which may well require us to conduct due diligence on our clients. This may include the use of third-party data and service providers that we will associate with your personal information.
Third parties providing services on our behalf
We use third parties to perform certain services on our behalf, such as hosting the Platform or performing the functions of the Platform, providing analytics on the use of the Platform, fulfilling orders, processing crypto transactions, sending email or other communications, providing marketing assistance, analyzing or improving, conducting promotions or other administrative services. We may share information about you with these third parties so that they can perform, provide or improve the services they provide to you and MULTI FACE DAO.
When you request that we share your information.
We may share information when you ask us to do so, for example, if you consent to receive communications from a third party, other Platform User, or if you interact with another third-party application.

Administrative Reasons, To Enforce and Protect Legal Rights
To the extent permitted by applicable law we will disclose your personal information pursuant to a law, regulation, court order, or other legal request or process, such as disclosure to law enforcement or other government officials or agencies in connection with any investigation, for example fraud, infringement of intellectual property rights, or any other activity that is or may be illegal or may expose MULTI FACE DAO, you or another person to legal liability. This disclosure may include legal requests when we believe in good faith that a response is required by law, regulation, court order, or other legal request or process in a particular jurisdiction, affects users in that jurisdiction, and complies with international standards.

We will disclose your personal information when necessary to exercise, enforce, establish or defend our legal rights. For example, we may review your account information to investigate allegations of hacking or violations of the applicable Terms of Service. We will disclose your personal information to our legal and other advisors, consultants, law enforcement or other government agencies.
Protection of Others
We will disclose your personal information to third parties when we believe disclosure is necessary to protect the rights, property, or safety of another. For example, we disclose personal information related to an account on the Platform if we believe in good faith that the account on the Platform is being used in ways that are detrimental to others or are contrary to applicable Terms of Service.
Business Transfers
In evaluating or engaging in a sale of assets, merger, acquisition, reorganization, bankruptcy, or other transaction, we reserve the right to disclose, transfer, or assign your personal information and communications. By providing your personal information, you agree that we may transfer such information to the acquiring entity without your further consent.


Our Platform is intended for a general audience and may not be used by persons under the age of 18. For this purpose, when creating an account on the Platform, we ask you to go through verification by providing official documents confirming your age and your identity.
In addition, in order to maintain a full range of services, the Platform restricts access to its services for US citizens.


Please note that if you choose not to provide us with certain personal information, we may not always be able to provide you with the relevant MULTI FACE DAO product or service that you request. For example, without providing an email address, you will not be able to create an account on the Platform.
If you have an account on the Platform, you may access, review, correct or update certain personal information collected about you, and deactivate or delete your account. If you have any concerns about how we use your personal information, if you would like to access, correct or delete the personal information you have provided to us, please contact us
Retention Period
We retain your personal information so that you can continue to use the MULTI FACE DAO Services, for as long as it is required to fulfill the relevant purposes described in this Privacy Policy, and as required by law, such as for tax and accounting purposes. , compliance with anti-money laundering laws or as otherwise communicated to you.
When you request that we delete your personal information, we will take commercially reasonable steps to remove it from our active databases but will keep original information consistent with our business practices to the extent that it is consistent with the purposes of the Platform (for example, for purposes of dispute resolution, enforcement of agreements, complying with legal requirements, recordkeeping, backup, and document retention).


MULTI FACE DAO takes commercially reasonable security measures to protect the information provided to us. We design our systems with your security and privacy in mind. We have appropriate security measures in place to prevent accidental loss, use or unauthorized access to, alteration or disclosure of your information. We work to ensure the security of your personal information during transmission and storage using encryption protocols and software. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information. In addition, we restrict access to your personal information to only those employees, agents, contractors and other third parties who need it for their work.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure and you use our Platform and transmit information to us at your own risk.
In addition, our security procedures mean that we may ask you to verify your identity to protect you from unauthorized access to your account password. We recommend that you use a unique password for your account on the Platform that is not used for other online accounts and log out of it when you are done using the shared computer.


MULTI FACE DAO is a data controller for the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”); and "personal information" used in this Privacy Policy is "personal data" as defined in Article 4(1) of the GDPR. In some cases, the Platform is also the data controller.
This applies to Platform Users from the EU and UK .
If you have any questions about how we use your personal data or protect your rights regarding your personal data, please contact us
The scope of this notice extends to the use of your personal data, whether through the Platform or otherwise. We process your personal data for the purposes set out below.
Legal Framework for Data Processing
The Platform processes your information where there are legitimate grounds to do so.
Performance of the Services
We process your data to operate our Platform, to provide or support our products and services, or for any other reason you request or authorize. This includes, for example, using your information to:
to manage your account on the Platform;
to organize your participation on the Platform as a Platform User or a potential Platform User;
to support the functionality of the Platform;
to organize the functioning of smart contracts of the Platform;
to maintain our Platform in accordance with this Privacy Policy and the applicable Terms of Service;
to provide customer service.
We process your data based on your consent where consent is a legal framework for such processing. This processing includes MULTI FACE DAO providing you with:

newsletters, direct emails and surveys about our Platform; as well as some other marketing functions.
If MULTI FACE DAO relies on your consent as a legal framework for processing your personal data, you have the right to withdraw your consent to further use of your personal information at any time.
Legitimate Interest
We process your data if the Platform has a legitimate interest in doing so. This includes, for example, processing your information to:
provide you with the customer service or technical support you have requested;
debugging and improving current and creating new processes of the Platform;
providing you with certain information, personalizing your experience of using the Platform with us and communicating with you in accordance with your applicable marketing preferences;
monitor activity on the Platform to prevent or detect any fraudulent use of the Platform;
prevent or detect any fraudulent schemes;
and to establish, exercise or defend legal claims or in connection with any court or jurisdiction.
Your Rights to Your Information
You have a number of rights regarding your privacy and the protection of your personal information. You have the right to request access to, correct and delete your personal information, and request data portability. You can also object to our processing of your personal information or ask us to restrict the processing of your personal information in certain cases. In addition, when you consent to our processing of your personal information for a specific purpose, you may withdraw your consent at any time. If you would like to exercise any of your rights, please email us at These rights may be limited in some situations - for example, when we can demonstrate that we have a legal requirement to process your personal data.
Right to Access:
You have the right to obtain confirmation that your personal information is being processed and to receive a copy of it, as well as certain information related to its processing.
Right to Correction:
You can request that your personal information that is inaccurate be corrected and added to it. You can also change your personal information in your account at any time.
Right to deletion:
In some cases, you may have your personal information deleted. To do this, if you have an account on the Platform, you can send a request to delete your personal information or transfer it to third parties via
Right to object:
For reasons related to your particular situation, you may object to the processing of your personal information. For example, you have the right to object when we rely on a legitimate interest or when we process your data for direct marketing purposes.
Your rights and complaints
Your right to complain to the data protection authority in the country where you live or work, or where you believe a violation has occurred, remains unaffected.
International Data Transfer
Your information will be collected, processed and stored directly by:
- for personal data of citizens from Europe and the UK, on Hetzner servers.
- for citizens of Russia, on Yandex.
In addition, information may be transferred to other countries where the Platform or third party business partners have facilities or business operations, which may include countries outside the UK or the EU. Where we are required by law to apply appropriate security measures to protect your personal information, we use methods approved by the European Commission to do so.
For each of the rights described above, please contact us


As set out in the International Transfers section, your information will be collected, processed and stored directly on or transferred to officially approved and secure servers, and may also be transferred to other countries where the Platform or our third-party business partners have facilities or business operations. Your personal information will be made available to law enforcement and/or regulatory authorities in accordance with the applicable laws of such countries.
Regardless of where the information is located, MULTI FACE DAO takes commercially reasonable steps to protect your privacy rights in accordance with this Privacy Policy. If you do not agree to the collection, processing, storage and transfer of your information, please do not provide us with your information and stop using our Platform.


To contact us about this Privacy Policy only:
To contact us for other questions:
as early as December 2022
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