Privacy Policy

Last Updated: February 2026

Introduction

This Privacy Policy (“Policy”) explains how personal data is collected, used, processed, and protected when you access or use the blockchain-based online entertainment platform and related services (the “Platform”).

This Policy describes how personal data is handled in connection with the Platform and its associated features.

We are committed to ensuring transparency in data processing practices and to complying with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and, where applicable, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).

By accessing or using the Platform, you acknowledge that you have read and understood this Policy.

1. Scope of This Policy

This Policy describes:

  • The types of Personal Data we collect and how we obtain it — including information you provide directly, and information collected automatically through your use of the Platform.

  • How we use, process, and store your Personal Data.

  • The legal bases for processing your Personal Data under applicable data protection laws.

  • How we share your Personal Data with third parties.

  • The security measures we implement to protect your Personal Data.

  • Your rights in relation to your Personal Data, and how you can exercise them.

"Personal Data" refers to any information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, to a natural person. This may include, for example, identifiers such as wallet addresses, usage patterns, and transaction data associated with your interactions on the Platform.

2.Data Controller

The G Coin ecosystem and associated blockchain-based functionalities are operated by Playnance OÜ, a private limited company duly incorporated under the laws of Estonia (“Playnance”).

Playnance acts as the data controller responsible for the collection and processing of Personal Data in connection with the G Coin ecosystem and related services.

If you have any questions about this Policy or your Personal Data, or if you would like to exercise your data protection rights, you may contact us at [email protected]envelope or via our official support channels.

3. Collection of Personal Data

We collect Personal Data in the following ways:

  • When you register an account or connect your crypto wallet to the Portal and Platform.

  • When you engage in peer-to-peer transactions using G Coin on the Platform.

  • When you interact with us through official communication channels, such as customer support.

  • When we automatically collect data about your activity on the Platform, including usage patterns, engagement metrics, and device information, using cookies and similar tracking technologies.

4. No Obligation to Provide Personal Data

Providing Personal Data is not mandatory; however, certain features of the Platform require a crypto wallet connection. Without providing this data, you may be unable to fully access or use certain functionalities of the Platform.

Some data processing, such as marketing communications and the use of non-essential cookies or tracking technologies, requires your consent. You may refuse or withdraw consent for these optional purposes at any time without affecting your access to core Platform features, although some personalized services or offers may be limited as a result.

5. Types of Personal Data We Collect

We collect and process the following categories of Personal Data:

Personal Data Collected Upon Registration

  • Crypto Wallet Address used to link your account and facilitate Platform transactions.

  • When you register using a third-party identity provider (such as through social login or email-based authentication), we may receive certain information linked to your account, depending on your privacy settings. This may include your full name, email address, profile image or icon, and phone number. We may not use all of this data but collect it as part of the initial authentication process. Your profile image or icon may be displayed on the Platform in areas such as user avatars, leaderboards, or jackpot listings. This information is shared with us after you approve the connection during the login process.

Personal Data Collected During Platform Use

  • Transaction history, including predictions, winnings, and losses.

  • Betting and trading preferences to support AI-driven predictions and peer-to-peer engagement features.

  • Platform activity data such as gameplay frequency, interaction patterns, and engagement metrics.

Know Your Customer (KYC) Data (where applicable)

  • Identification data such as your full name, government-issued ID, date of birth, nationality, and proof of address.

  • Additional verification details submitted to comply with anti-money laundering (AML), counter-terrorism financing (CTF), and financial regulations.

Know Your Business (KYB) Data (in the context of partnership programs and licensing arrangements)

  • In connection with our partnership programs or licensing agreements, we may collect Personal Data of individuals acting on behalf of corporate customers. This may include identification documents, contact details, role within the company, and other verification data required for due diligence or legal compliance purposes.

Personal Data You Provide Voluntarily

  • Information you share when submitting support inquiries or communicating with us.

  • Content you voluntarily submit, such as feedback, reviews, or uploaded materials related to your experience with the Platform.

Automatically Collected Data

  • Device type, operating system, browser information, IP address, and general location derived from your connection.

  • Data collected via cookies and similar tracking technologies to improve Platform functionality, security, and user experience.

Third-Party Data

  • Data we may receive from external service providers (e.g., analytics, fraud prevention tools) or public sources to support Platform operations and compliance efforts.

5A. Data Processed in Connection with Partnership Programs and Licensing Arrangements

In the context of our partnership programs and licensing agreements, we may collect and process Personal Data relating to individuals who represent or act on behalf of legal entities. This may include data about:

  • Company directors, officers, or authorized representatives;

  • Ultimate Beneficial Owners (UBOs);

  • Compliance or legal points of contact;

  • Signatories to legal agreements.

The types of Personal Data collected may include full name, professional title, government-issued identification documents, contact details (such as email address and phone number), and supporting documentation required for business verification or compliance checks (e.g., KYC/KYB, AML, or sanctions screening).

This information is processed for the purposes of:

  • Conducting due diligence and compliance assessments in line with applicable financial and anti-money laundering (AML) regulations;

  • Executing and managing contractual relationships with partners and licensees;

  • Preventing fraud and ensuring business integrity;

  • Complying with our legal obligations under local and international regulations.

We process this Personal Data based on legal obligation, legitimate interest or contractual necessity, depending on the nature of the relationship and applicable laws.

6. Purposes of Processing Personal Data

We process your Personal Data for the following purposes:

  • To register and manage your user account, including enabling access to the Platform, processing transactions, and maintaining your profile.

  • To facilitate peer-to-peer transactions and G Coin payments, including on-chain deposits and rewards.

  • To comply with legal and regulatory requirements, including those related to anti-money laundering (AML), counter-terrorism financing (CTF), fraud prevention, and responsible gaming.

  • To detect, investigate, and prevent fraudulent, suspicious, or unauthorized activities that may compromise the security or integrity of the Platform.

  • To provide customer support and resolve user inquiries or technical issues.

  • To improve Platform performance and user experience by analyzing user interactions, preferences, and behavior.

  • To fulfill obligations related to our partnership programs, licensing arrangements, and associated due diligence or compliance reviews.

  • To send you service-related notifications and updates, and — where permitted by law or based on your consent — promotional or marketing communications.

This may include browser-based or device notifications (push notifications) delivered through our Progressive Web App (PWA) if you have installed or saved it to your home screen and granted permission to receive such updates. These notifications may include new game releases, promotional offers, or service-related alerts. You can withdraw consent or disable notifications at any time through your browser or device settings.

Personalized Notifications and Recommendations If you grant permission to receive push notifications, we may analyze your activity on the Platform (such as the types of games you play, your engagement frequency, or preferred genres) to personalize the notifications you receive. These notifications may include recommendations for new games, tournaments, or rewards you are likely to enjoy. This processing is based on your consent and our legitimate interest in improving user experience. You can withdraw your consent or disable notifications at any time through your browser or device settings.

We ensure that all processing of Personal Data is based on a valid legal basis, which may include the performance of a contract, compliance with a legal obligation, legitimate interests pursued by us or a third party, or your explicit consent where required.

For a detailed breakdown of the legal bases corresponding to each processing purpose, please refer to Annex A: Legal Bases for Data Processing.

7. Payment and Transaction Security

All transactions conducted on the Platform are secured through blockchain technology, providing transparency, immutability, and enhanced security.

  • We do not store sensitive payment details such as credit card information or bank account numbers.

  • All on-chain transactions are recorded transparently on the blockchain, ensuring verifiability and traceability.

  • Payments, payouts, and commissions are processed automatically via smart contracts to ensure timely and accurate settlements.

  • Partners payouts and commissions are typically processed daily at 12 PM GMT.

  • We implement robust security measures to protect your Personal Data and transaction information, including encryption, access controls, and monitoring for suspicious activity.

  • While we take extensive measures to secure the Platform and user data, no system is completely immune to risks. Users are encouraged to secure their crypto wallets and use best practices for account protection.

8. Data Sharing and Third-Party Services

We do not sell your Personal Data. However, we may share your Personal Data with trusted third-party service providers in order to provide, maintain, and improve the Platform, comply with legal obligations, and protect our users.

These third parties may include:

  • Payment processors and financial service providers, who may receive limited Personal Data necessary to facilitate payment transactions and comply with financial regulations. Please note that payments made through third-party payment systems are typically processed directly by those providers, who collect and handle your payment information independently.

  • KYC and identity verification providers, which we may engage to assist with anti-money laundering (AML), know your customer (KYC), and other compliance checks. These providers would process identity documents and other information necessary for verification purposes.

  • Game providers and platform service providers who process Personal Data related to gameplay, user interactions, and platform operations to enable the delivery of games and services.

  • Advertising and Campaign Partners. We may share limited data with third-party advertising and marketing partners to deliver, customize, and measure the effectiveness of promotional campaigns. These partners may include social media platforms, search engines, and advertising networks (such as, but not limited to, Google, Meta, X (formerly Twitter), and Snapchat).

  • Analytics and performance service providers, who help us analyze Platform usage and improve features and security.

  • Regulatory authorities and law enforcement agencies, when required by applicable laws or regulations.

All third parties receiving your Personal Data are contractually obligated to implement appropriate data protection and security measures and to use your Personal Data solely for the purposes we specify.

We take reasonable steps to ensure that your Personal Data is processed securely and in accordance with this Privacy Policy and applicable data protection laws.

9. Use of Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on the Platform. These technologies help us:

  • Remember your preferences and settings.

  • Analyze how you use the Platform to improve functionality and user experience.

  • Provide personalized content and marketing communications (where you have given consent).

You can control or disable cookies through your browser settings; however, disabling certain cookies may affect your ability to use some features of the Platform.

In jurisdictions where required by law (such as the European Union), we will obtain your consent before placing non-essential cookies on your device.

For more information about cookies and how we use them, please see our Cookies Policy.

In addition to cookies, we may use browser-based push notification technologies to deliver updates directly to your device. These notifications are only sent if you explicitly opt in and can be disabled at any time in your browser or device notification settings.

We may use cookies, local storage, or similar technologies to remember your preferences and tailor push notifications to your interests. This helps us send you updates and game recommendations that are more relevant to you. You can control or disable these technologies and manage notification preferences through your device or browser settings. In jurisdictions where required by law, we obtain your explicit consent before enabling personalized notifications.

10. Your Rights Regarding Personal Data

As a user of the Platform, you have the following rights concerning your Personal Data:

  • Right to Access: You may request a copy of the Personal Data we hold about you.

  • Right to Rectification: You may request correction of any inaccurate or incomplete Personal Data.

  • Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data when there is no overriding legal obligation to retain it. Upon a valid deletion request, we will delete or irreversibly anonymize your off-chain Personal Data, including email address, authentication credentials, display name, profile image, internal identifiers, and any wallet linkage stored by us.

  • Right to Restrict Processing: You may request that we limit the processing of your Personal Data in certain circumstances.

  • Right to Data Portability: You may request that we provide your Personal Data to you or to another data controller in a structured, commonly used, and machine-readable format.

  • Right to Object: You have the right to object to the processing of your Personal Data based on legitimate interests or for direct marketing purposes.

  • Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time.

Please note that certain interactions with the Platform occur on public blockchain networks. Blockchain transaction records are decentralized and immutable by design and cannot be altered or erased by us. However, once account-related Personal Data is deleted, we no longer maintain any link between such blockchain records and an identifiable individual.

We may retain anonymized or aggregated data that no longer identifies you, including system analytics and performance statistics, as permitted by applicable law.

California residents also have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

  • Right to Know: You may request information about the categories and specific pieces of Personal Data we have collected about you.

  • Right to Delete: You may request the deletion of Personal Data we have collected, subject to legal exceptions.

  • Right to Correct: You may request that we correct inaccurate Personal Data.

  • Right to Opt-Out of Sale or Sharing: California residents have the right to opt out of the sale or sharing of their Personal Data. Playnance does not sell or share Personal Data as defined under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). We do not engage in cross-context behavioral advertising.

To exercise any of these rights, please contact us at [email protected]envelope or through our official support channels. We may require verification of your identity before processing your request to protect your privacy and security.

We aim to respond to all valid requests promptly and in accordance with applicable data protection laws.

11. Data Retention Policy

We retain your Personal Data only for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Privacy Policy, or to comply with our legal, regulatory, or contractual obligations.

Retention periods may vary depending on the type of data and the context in which it is processed:

  • Account and transaction data (e.g., wallet addresses, G Coin transactions, gameplay history) may be retained for up to seven (7) years after account closure to comply with anti-money laundering (AML), tax, and financial regulations.

  • KYC and KYB records, where collected, may be retained in accordance with applicable legal retention obligations, typically for five (5) to seven (7) years, depending on jurisdiction.

  • Support inquiries and correspondence may be retained for up to twelve (12) months following the resolution of the inquiry.

  • Analytics and technical logs may be retained for shorter periods (e.g., 90 days to 12 months) depending on operational needs and legal requirements.

If we are not legally required to retain certain Personal Data, you may request its deletion earlier. We will assess such requests in accordance with applicable data protection laws and confirm whether deletion is possible.

When retention is no longer necessary, we securely delete or anonymize your Personal Data, unless a longer retention period is required or permitted by law.

12. International Data Transfers

Playnance operates globally. As a result, your Personal Data may be transferred to and processed in countries outside of your country of residence, including jurisdictions that may not provide the same level of data protection as your local laws.

Where Personal Data is transferred outside the European Economic Area (EEA), United Kingdom, or other jurisdictions with data transfer restrictions, we ensure that such transfers are carried out in accordance with applicable data protection laws. This may include:

  • Using Standard Contractual Clauses (SCCs) approved by the European Commission or relevant supervisory authorities;

  • Relying on adequacy decisions where applicable (e.g., countries recognized as providing adequate protection);

  • Implementing other appropriate safeguards, including contractual and organizational measures to protect your data.

By using the Platform, you understand that your Personal Data may be transferred to and processed in countries where data protection standards may differ from those in your jurisdiction.

If you would like more information about the international transfers of your Personal Data or the safeguards we apply, please contact us at [email protected]envelope.

13. Security Measures to Protect Data

We take the security of your Personal Data seriously and implement appropriate technical and organizational measures to protect it against unauthorized access, loss, misuse, alteration, or disclosure.

Security measures implemented by the Platform include:

  • Blockchain-based encryption to secure on-chain transactions and ensure data immutability.

  • Smart contracts to automate and secure financial transactions within the Platform.

  • Access controls and role-based permissions to limit data access only to authorized personnel.

  • Secure communication protocols (such as HTTPS and TLS) to protect data in transit.

  • Monitoring and auditing tools to detect suspicious activity and potential threats.

  • Internal policies and staff training on data protection and information security best practices.

Despite our efforts, no system is completely immune to risk. We therefore encourage users to take precautions to protect their own data, including securing crypto wallets, using strong passwords, and enabling two-factor authentication where available.

If you become aware of any potential security vulnerabilities or unauthorized access to your account, please contact us immediately at [email protected]envelope.

14. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us by email at [email protected]envelope or through our official support channels available on the website.

We are committed to addressing your inquiries and protecting your privacy in accordance with applicable data protection laws.

Annex A: Legal Bases for Data Processing

Purpose of Processing

Legal Basis under GDPR (Article 6)

Register and manage user accounts

Performance of a contract (Art. 6(1)(b))

Facilitate peer-to-peer transactions and G Coin payments

Performance of a contract (Art. 6(1)(b))

Comply with legal and regulatory requirements

Compliance with a legal obligation (Art. 6(1)(c))

Detect, investigate, and prevent fraudulent activity

Legitimate interest (Art. 6(1)(f))

Provide customer support and respond to inquiries

Performance of a contract (Art. 6(1)(b)) and/or Legitimate interest (Art. 6(1)(f))

Analyze usage and improve Platform functionality

Legitimate interest (Art. 6(1)(f))

Send service-related notifications and updates

Performance of a contract (Art. 6(1)(b))

Send marketing or promotional communications

Consent (Art. 6(1)(a))

Manage partnership programs and licensing arrangements

Performance of a contract (Art. 6(1)(b)), Compliance with legal obligation (Art. 6(1)(c)), or Legitimate interest (Art. 6(1)(f)) depending on context


Notes:

  • Where processing relies on consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out before your withdrawal.

  • The legal basis for processing may vary depending on your jurisdiction and the specific context of the processing activity. This annex primarily reflects the requirements of the GDPR.

  • Privacy laws in other jurisdictions, including the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), do not require specification of legal bases but emphasize transparency regarding data collection, use, sharing, and consumer rights.

  • In cases where more than one legal basis applies to a processing purpose, the applicable basis will be specified as appropriate.

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