This Policy applies to the collection of your personal data, as well as to the use of cookies and similar technologies on the JoyFlick platform, which includes our website, mobile applications, and related services (collectively, the "Platform"), including any games, contests, tournaments, matchmaking, promotions, and withdrawal functionality.

The data controller is Elympics, Inc., with its registered seat in Kingstown, Saint Vincent and the Grenadines ("Elympics", "We" or "Our").

Your privacy is important to us. We recognize that your privacy is very important to you and that it is your right to control what information we process about you and how we process it. We know that providing personal data is an act of trust and we take that trust seriously. Elympics will never sell, rent or otherwise disclose your personal data, except as outlined in this Privacy and Cookie Policy, provided that we have an appropriate legal basis for such disclosure. Elympics takes appropriate steps to ensure the security of your data.

By your continued use of our Services following the posting of this Privacy Policy, you agree to this Privacy Policy. This Privacy Policy forms part of and should be read in conjunction with our Terms of Service.

1. What Data We Process

In the course of your use of our Services, we collect the following personal data:

• Registration Data: Your e-mail address and password, if you choose to create a User Account with us.
• Identity and Verification Data (KYC): Information used to verify your eligibility, age, and location, as well as data required to conduct sanctions screening and fraud checks.
• Wallet Authentication Data: Information used to create and authenticate your non-custodial cryptographic wallet via third-party providers like Privy.
• Blockchain and Transaction Data: Public wallet addresses, records of Top-Ups (deposits of supported digital assets like USDC), network fees, and withdrawal transaction history.
• Financial and Withdrawal Data: Supported digital asset wallet addresses, network details, and information required by third-party virtual credit card partners ("Card Partners") to process withdrawals.
• Gameplay and Technical Data: Information regarding device performance, connectivity, latency, operating system differences, and scoring or skill metrics used for matchmaking, outcome determination, and ensuring fair play.
• User Content: Any content you submit, such as profiles, images, and feedback.
• Usage Data: Information about your interaction with the Platform and your use of Elympics Services (how often you use our Services, what materials you choose to access, etc.).

2. Purpose and Legal Basis of Processing

We collect and process your data to:

• Operate the Platform: Create and manage your account, tailor our Services to your needs, and contact you. (Legal basis: Performance of a contract)
• Facilitate Gameplay and Transactions: Use smart contracts, session keys, and technical controls to enable gameplay, process entry fees, distribute prizes, manage internal currencies (Diamonds and Bonus Dollars), and process refunds or crypto withdrawals. (Legal basis: Performance of a contract)
• Ensure Fair Play and Security: Monitor for cheating, exploit bugs, unauthorized tools, or fraudulent transactions, and invalidate suspicious results. (Legal basis: Legitimate interest and legal obligation)
• Marketing: Send you marketing e-mails, provided that you did not opt out. In doing so, we pursue our legitimate interest in direct marketing of our own Services. We may use collected data to adjust the Services we provide to meet your needs (e.g., to display tailored advertisements). We do not use your personal data in a way that would result in automated decision-making that could affect your legal rights. (Legal basis: Legitimate interest)

3. Sharing Data with Third Parties

The Platform interoperates with third-party services. We entrust the processing of your personal data to carefully selected entities who act on our behalf or facilitate Platform features. These include:

• Wallet Providers: Cryptographic wallets are created and authenticated via Privy (or another provider we designate).
• Blockchain Networks: The Platform interacts with public blockchain infrastructure (such as the Base network). Transaction data and wallet addresses will be broadcast and recorded on public ledgers.
• Withdrawal and Card Partners: Third-party partners that provide virtual credit cards and related services for withdrawal requests.
• Game Developers: Third-party developers who provide games on the Platform.
• Verification Providers: Third-party providers used for identity verification (KYC), age, and location checks.
• Analytics Providers: Google Analytics, Firebase, and Hotjar, used to calculate visits, analyze interactions, and improve operation.

We may also be obliged to share your personal data with competent authorities if they approach us with a legally backed request (e.g., a court order). If your data is transferred outside your jurisdiction, we ensure adequate safeguards are in place, such as Standard Contractual Clauses.

4. Data Retention and Your Rights

• Right to object: You have the right to object to the processing of your data when it is based on legitimate interest (e.g., marketing).
• Correction and deletion: You have the right to request that we correct or delete your data if information is incorrect or outdated, or if we no longer have a legal basis to process it. If you request deletion, we will comply unless there is an overriding legal interest (e.g., defense of claims, fraud investigations, or legal obligations such as accounting or tax retention).
• Access and portability: You also have the right of access to your data, to request a copy of data that we process about you, as well as the right to data portability and restriction of processing.
• Duration of processing: We process your personal data only for as long as necessary for the purposes for which it was collected. In determining retention periods, we consider whether you still use our Services, whether you still maintain an account, and whether legal obligations require retention.
• Contact and complaints: If you have questions about processing or want to exercise your rights, contact us at [email protected]. You also have the right to file a complaint with a data protection supervisory authority.

Important Blockchain Limitations

If you request deletion of your Platform account, we will comply subject to legal retention requirements. However:

• Wallet persistence: Deleting your Platform account does not necessarily delete your non-custodial wallet.
• Immutability: Because blockchain transfers and Top-Ups are final and confirmed on-chain, Elympics cannot delete or alter transaction histories, network fees, or wallet addresses once they are published on a public blockchain network.
• Investigations: We may retain necessary data for pending fraud or terms-violation investigations, as well as for accounting or tax purposes.

5. Use of Cookies and Similar Technologies

In order to improve operation of our Platform, we use cookies, web beacons, device fingerprinting, and similar technologies. We also use Google Analytics, Firebase, and Hotjar tools.

Cookies are text files containing small amounts of information that are downloaded to your computer, mobile, or other device when you visit a website. They are sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies help websites recognize a user device, remember preferences, improve navigation, and provide better user experience.

Types of cookies used

1. Persistent cookies: These remain on a user device for the period specified in the cookie and are activated each time the user visits the website that created that cookie.
2. Session cookies: These allow website operators to link user actions during a browser session. A session starts when a browser window opens and ends when it closes. Session cookies are temporary and are deleted when the browser closes.
3. Strictly necessary cookies: These enable services you specifically requested. For these cookies, consent is not required. They are essential for core website functionality.
4. Performance cookies: These collect anonymous information about page usage and website errors. They do not identify individual users and are used to improve website performance.
5. Functionality cookies: These remember your preferences (such as language or region) to provide more personalized functionality.
6. Targeting or advertising cookies: These collect information about browsing habits to provide relevant advertising and measure ad effectiveness. They are often placed by advertising networks with our permission.

Other technologies and tools

• Web beacons (pixel tags): Transparent image files used to monitor your journey and interactions with the website.
• Device fingerprinting: Technology used to collect device attributes (browser, operating system, plugins, time zone, and other settings) for security and identification purposes.
• Google Analytics and Firebase: Tools we use to calculate visits, understand feature usage, and improve website operation. Learn more: Google Analytics privacy overview. You can opt out via the Google Analytics browser add-on.
• Hotjar: Tool used to analyze how users interact with our website. Learn more in Hotjar Privacy Policy.

Cookies and similar technologies may be used for statistical purposes, personalization, and adapting website structure and content to user preferences. Some cookies may be linked to external services (including advertising platforms).

Handling and use of cookies is generally enabled automatically, but you can change these settings at any time in your browser settings. More information is available at All About Cookies.