Privacy Policy

1. Introduction

2. Information We Collect

We collect several categories of information from and about users of our Platform. The types of information we collect depend on how you interact with us.

Personal Information You Provide Directly

• IDENTITY AND CONTACT DATA: Full name, username, email address, phone number, date of birth, residential address, city, state/province, postal/ZIP code, country of residence, and government-issued identification numbers.
• ACCOUNT DATA: Username, password (hashed and encrypted), account preferences, profile picture/avatar, nickname, and account settings.
• FINANCIAL DATA: Cryptocurrency wallet addresses, transaction history, deposit and withdrawal records, payment-provider metadata, and, where supported or required, limited payment method, bank, or tax information. Payment card or bank details, if offered, are processed by payment providers; we do not store full card numbers.
• KYC/VERIFICATION DATA: Government-issued photo identification (passport, driver's license, national ID card), selfie photograph with ID, proof of address documents (utility bills, bank statements), social security number or equivalent (for US users as required), and any other identity verification documents.
• COMMUNICATION DATA: Records of your correspondence with us, including customer support inquiries, emails, chat messages, dispute correspondence, and any other communications.
• USER-GENERATED CONTENT: Profile pictures, profile descriptions, chat messages sent to other users, and any other content you create or share on the Platform.

Information Collected Automatically

• DEVICE AND TECHNICAL DATA: IP address, device type and model, operating system and version, browser type and version, device identifiers (including advertising IDs), mobile network information, screen resolution, language settings, and time zone.
• USAGE AND ACTIVITY DATA: Pages visited, features used, time spent on pages, links clicked, tournament entries and picks submitted, transactions initiated, search queries, referring/exit URLs, scroll depth, mouse movements, and interaction patterns.
• LOCATION DATA: Precise geolocation data (with your permission), IP-based approximate location, and GPS coordinates (for mobile app users who enable location services). We use location data for geofencing compliance and regional service availability.
• COOKIES AND TRACKING DATA: Session cookies, persistent cookies, authentication tokens, and analytics identifiers. See Section 10 for our detailed Cookie Policy.
• SERVER LOG DATA: Timestamp of access, pages requested, HTTP status codes, data transfer volumes, and error logs. These are automatically collected by our web servers and cloud infrastructure.

4. How We Use Your Information

We use the information we collect for the following specific purposes:

• ACCOUNT MANAGEMENT: Creating, maintaining, and securing your account; authenticating your identity at login; processing account updates and preferences; managing account verification and recovery.
• TOURNAMENT OPERATIONS: Processing your tournament entries; recording and displaying your picks; calculating and verifying scores; determining winners and rankings; distributing prizes; displaying leaderboards and statistics.
• FINANCIAL PROCESSING: Processing deposits and withdrawals; maintaining transaction histories; reconciling accounts; calculating fees, rake, and jackpot contributions; generating financial reports; facilitating cryptocurrency transactions.
• IDENTITY VERIFICATION: Conducting KYC checks; verifying age (18+ requirement); validating identity documents; screening against sanctions and PEP lists; preventing multi-accounting; ensuring compliance with AML regulations.
• COMMUNICATIONS: Sending account-related notifications (password resets, transaction confirmations, prize notifications); providing customer support and responding to inquiries; sending service announcements and updates; requesting feedback through surveys.
• PLATFORM IMPROVEMENT: Analyzing usage patterns to improve user experience; developing new features and services; testing and debugging; optimizing platform performance; conducting research and analytics.
• SECURITY AND FRAUD PREVENTION: Detecting and preventing fraudulent activity; monitoring for suspicious transactions and multi-accounting; enforcing Terms of Service; protecting against unauthorized access; maintaining platform integrity; conducting security audits and investigations.
• LEGAL COMPLIANCE: Complying with applicable laws and regulations; responding to legal process and law enforcement requests; filing required reports with regulatory authorities; maintaining records for tax and audit purposes.

5. Information Sharing and Disclosure

We do not sell your personal information to third parties for monetary consideration. We may share your information in the following circumstances:

• SERVICE PROVIDERS: Companies that perform services on our behalf, including: cloud hosting (Supabase, Vercel), payment processing providers such as NowPayments and any card or fiat providers we enable, identity verification, email delivery, SMS notifications, customer support platforms, and analytics providers. These providers are contractually bound to process data only as instructed by us.
• PAYMENT PROCESSORS: Financial institutions and payment service providers that process your deposits and withdrawals. We share only the information necessary to complete transactions.
• LEGAL AND REGULATORY AUTHORITIES: When required by law, court order, subpoena, or governmental regulation. We may also share information to report suspicious activity to financial intelligence units, law enforcement, or regulatory bodies as part of our AML/KYC obligations.
• PROTECTION OF RIGHTS: When we believe disclosure is necessary to: (a) protect our rights, property, or safety; (b) protect the safety of our users or the public; (c) investigate and defend against legal claims; (d) enforce our Terms of Service; or (e) detect, prevent, or address fraud, security, or technical issues.
• BUSINESS TRANSFERS: In connection with a merger, acquisition, reorganization, sale of assets, financing, or bankruptcy. If such a transaction occurs, we will notify you before your information is transferred and becomes subject to a different privacy policy.
• AFFILIATES AND SUBSIDIARIES: Within our corporate group for internal administrative purposes, provided they adhere to equivalent data protection standards.
• WITH YOUR CONSENT: To any other third party when you have provided explicit consent for such sharing.

8. Data Security

We implement and maintain commercially reasonable administrative, technical, and physical security measures designed to protect your personal information against unauthorized access, disclosure, alteration, and destruction. Our security measures include:

• ENCRYPTION: All data transmitted between your browser and our servers is encrypted using TLS 1.3. Sensitive data at rest is encrypted using AES-256 encryption. Passwords are hashed using bcrypt with unique salts.
• ACCESS CONTROLS: Role-based access controls ensure that only authorized personnel with a legitimate business need can access personal information. Multi-factor authentication is required for administrative access.
• INFRASTRUCTURE SECURITY: Our infrastructure is hosted on SOC 2 Type II compliant cloud providers. We employ firewalls, intrusion detection systems, DDoS protection, and continuous security monitoring.
• SECURE DEVELOPMENT: We follow secure software development practices including regular security testing, vulnerability scanning, code reviews, and dependency audits.
• INCIDENT RESPONSE: We maintain a documented incident response plan for data breaches and security incidents.
• EMPLOYEE TRAINING: All employees and contractors with access to personal data receive privacy and security training and are bound by confidentiality obligations.

9. Data Retention

• ACCOUNT DATA: Retained for the duration of your account plus seven (7) years after account closure to comply with tax, anti-money laundering, and other legal requirements.
• KYC DOCUMENTS: Identity verification documents are retained for five (5) years after account closure or the last transaction, whichever is later, as required by AML regulations.
• FINANCIAL RECORDS: Transaction records, deposit/withdrawal histories, and payment information are retained for seven (7) years to comply with tax and financial reporting laws.
• COMMUNICATIONS: Customer support communications and dispute records are retained for three (3) years after resolution.
• USAGE DATA: Anonymized usage and analytics data may be retained indefinitely for research and statistical purposes.
• COOKIES: Cookie data retention periods vary by cookie type. Session cookies expire when you close your browser. Persistent cookies expire according to their set expiration dates (typically 30 days to 2 years).

11. Your Data Protection Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information. We will respond to verified requests in accordance with applicable law:

• RIGHT TO ACCESS: You may request a copy of the personal information we hold about you and information about how we process it. Your first copy in any 12-month period is free; we may charge a reasonable fee for additional copies.
• RIGHT TO RECTIFICATION: You may request that we correct inaccurate or incomplete personal information we hold about you. You can update most account information directly through your profile settings.
• RIGHT TO ERASURE ("RIGHT TO BE FORGOTTEN"): You may request deletion of your personal information, subject to legal retention requirements. We may retain certain information as required by law (e.g., KYC records, financial transactions) even after account deletion.
• RIGHT TO DATA PORTABILITY: Where processing is based on consent or contract and carried out by automated means, you may request to receive your personal information in a structured, commonly used, machine-readable format and have it transmitted to another controller.
• RIGHT TO RESTRICTION: You may request that we restrict processing of your personal information in certain circumstances, such as when you contest the accuracy of the data or object to processing.
• RIGHT TO OBJECT: You may object to processing based on legitimate interests, including profiling. You have an absolute right to object to processing for direct marketing purposes at any time.
• RIGHT TO WITHDRAW CONSENT: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

10. Cookies and Tracking Technologies

14. Children's Privacy

15. Changes to This Privacy Policy

16. Contact Us