•  Privacy Policy





    1. 101 Tokens Pty Ltd (ABN 13 627 451 398) (‘The Token Game’, 'us' or ‘we’) operates the platform known as ‘THE TOKEN GAME’ ('The Token Game Platform’).


    2. This Privacy Policy outlines how and why we collect, hold, use and disclose your (‘you’ or the ‘subscriber’) personal information. This Privacy Policy applies to your use of www.101tokens.com (the ‘Website’) and The Token Game mobile app (the ‘App’).


    3. By using the Website, downloading offered content or clicking ‘join’ when signing up for a user account on the Website or the App, you consent to the collection and use of your personal information in accordance with this Privacy Policy.


    What personal information do we collect and hold?


    4. We collect information about you and your interactions with us, for example, when you use the The Token Game Platform or contact us. The information we collect from you through the Website or the App may include, but is not limited to, your full name, email address, gender, date of birth, location (including postcode and country), university and information about your alcohol consumption and wellbeing.


    5. We may collect information about how you access, use and interact with the Website and App. This information may include:


    The location from which you have come to the site and the pages you visited; and technical data, which may include your IP address, the types of devices you are using to access the website, device attributes, browser type, language and operating system.


    6. We use cookies on the Website. A cookie is a small text file that the Website may place on your device to store information. We may use persistent cookies (which remain on your computer even after you close your browser) to store information that may speed up your use of our Website for any of your future visits to the Website. We may also use session cookies (which no longer remain after you end your browsing session) to help manage the display and presentation of information on the Website. You may refuse to use cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of the Website.


    7. We may from time to time collect sensitive information, including health information, from you with your consent.


    8. If you do not provide us with your personal information we may not be able to provide you with our services through The Token Game Platform, communicate with you or respond to your enquiries.


    9. If we publish a blog on the Website on your behalf, it will be available for both The Token Game Platform registered users and the general public to read. It may also be indexed by search engines.


    Why do we collect, hold and use your personal information?


    10. We collect, hold and use your personal information so that we can:


    - provide our services to you, including The Token Game Platform, and manage our relationship with you;

    - contact you, for example, to respond to your queries or complaints, or if we need to tell you something important.

    - comply with our legal obligations and assist government and law enforcement agencies or regulators; and

    - identify and tell you about other products or services that we think may be of interest to you.


    11. We may also use your personal information for our training purposes.


    12. We may also use your personal information for statistical purposes and generating reports for evaluating and improving The Token Game Platform services.


    13. We may disclose and use, aggregate, anonymous, pseudonymised or de-identified information about users for marketing, advertising, research, compliance, or other purposes. For example, we may use metadata relating to users' use of The Token Game platform and aggregate, anonymous, pseudonymised or de-identified user information to identify and analyse trends and patterns that may affect our quality of service or the operations of the 101 Tokens Platform, and improve our services.


    14. Your personal information may be aggregated, analysed and periodically published in research literature. In any publication of findings, information will be presented in such a way that you cannot be identified. If you wish to have your personal information withdrawn from any research evaluations, you can notify benny@101tokens.com.


    15. We may also use the personal information for advertising and direct marketing purposes including, but not limited to, sending surveys relating to your alcohol consumption and wellbeing and sending out newsletters and special offers. [These products and services may be offered by us, our related companies, our other business partners or our service providers.] [Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt out instructions provided in the communication.


    How do we collect your personal information?


    16. We will collect most personal information directly from you when you interact with us, including through your use of the Website and App.


    Who do we disclose your personal information to, and why?


    17. We may disclose your personal information to service providers so that they may perform services for us or on our behalf. Our service providers include providers of archiving, auditing, accounting, legal, business consulting, banking, and technology-related services.


    18. We may disclose your personal information to prospective purchasers of any interest in The Token Game Platform or our assets. If the ownership or control of all or part of our business changes, we may transfer your personal information to the new owner.


    19. We may also disclose your personal information to others third parties where:


    - we are required or authorised by law to do so;

    - you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances;

    - we are otherwise permitted to disclose the information under the Australian Privacy Act 1988 (Cth).


    20. We do not disclose your personal information to recipients which are located outside Australia.


    How do we store and hold personal information?


    21. We store most information about you in computer systems and databases operated by either us or our external service providers.


    22. We implement and maintain processes and security measures to protect personal information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure.


    23. Data transmissions over the Internet cannot be guaranteed to be fully and absolutely secure. While the Website, the App and our services have security measures in place designed to protect against the loss, misuse and alteration of the information under our control, we cannot ensure or warrant that your personal information will always be secure during transmission or protected from unauthorised access when stored.


    24. When you complete your profile on the App, you may choose to (when update available) link your profile to your Facebook and/or your X and/or your Instagram accounts. This is not a mandatory requirement. We cannot guarantee the security of your personal information if you choose to link your profile to Facebook and/or X and/or Instagram. If you choose at a later point in time to unlink your profile from Facebook and/or X and/or Instagram, traces of the link may remain online.


    25. Please contact us immediately if you become aware or have reason to believe there has been unauthorised use of your personal information in connection with the website or the app.


    26. We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the APPs.


    Accessing and Amending your Personal Information


    27. You may obtain access to or seek correction of your personal information by writing to us at one of the addresses set out below. We will reasonably endeavour to respond to your request within a reasonable time. You are responsible for advising us of any changes to your personal information. There is no charge for requesting access to your personal information but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).


    28. If you would like to delete your profile from the Website and the App, please inform us by writing to us at one of the addresses set out below. Please be aware there may be residual information left behind on our servers from your profile/personal information which is beyond our control.


    29. There are some circumstances in which we are not required to give you access to your personal information.




    30. If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us. Our contact details are set out below.


    31. We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.


    32. If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action which may be available.


    Contact details


    33. If you have any questions, comments, or concerns, please contact us at:


    Attention: 101 Tokens PTY LTD 618 Tomewin Mountain Road, Currumbin Valley, QLD, Australia


    Changes to the Privacy Policy


    34. This Privacy Policy is effective as of 17 December 2024. We may change this Privacy Policy from time to time, and you should review the terms of this Privacy Policy regularly. You may obtain a copy of our current policy from the Website or by contacting us at the contact details set out above.


    35. Your use of the website following any such changes to the Privacy Policy will confirm your acceptance of the updated Privacy Policy.