1. Data Controller

PLAY TO EARN GAMES, LLC is the data controller responsible for your personal data. For questions or to exercise your GDPR rights, contact us at:

PLAY TO EARN GAMES, LLC
2719 Hollywood Blvd, Hollywood, FL 33020
Email: privacy@cryptoplaystudio.com

2. Personal Data We Collect

We collect the following categories of personal data, as defined under GDPR:

• Identity and Contact Data: Name, email address, username, and cryptocurrency wallet address provided when you create an account or contact us.
• Blockchain Data: Public blockchain transaction data, such as wallet addresses, transaction IDs, and earned cryptocurrency or NFT rewards, recorded on public blockchains (e.g., Ethereum, Solana). This data is pseudonymous but may be considered personal data under GDPR if linked to an identifiable individual.
• Technical Data: IP address, device type, browser type, operating system, and other device identifiers collected automatically when you use the Services.
• Usage Data: Information about your interactions with the Services, such as pages visited, gameplay statistics, and timestamps.
• Cookies and Tracking Technologies: Data collected via cookies, web beacons, and similar technologies to improve functionality, analyze usage, and provide personalized content.

3. Legal Basis for Processing

We process your personal data based on the following GDPR legal bases:

• Consent (Article 6(1)(a)): For optional data collection, such as promotional emails or certain cookies, where you provide explicit consent.
• Contract (Article 6(1)(b)): To provide the Services, including account creation, gameplay, and Reward distribution.
• Legitimate Interests (Article 6(1)(f)): For improving the Services, ensuring security, and preventing fraud, provided our interests do not override your rights.
• Legal Obligation (Article 6(1)(c)): To comply with applicable laws, such as tax or anti-money laundering regulations.

4. How We Use Your Personal Data

We use your personal data to:

• Provide and maintain the Services, including processing in-game transactions and distributing cryptocurrency or NFT Rewards.
• Authenticate accounts and ensure the security of the Services.
• Communicate with you, including responding to inquiries and sending updates or promotional materials (with your consent).
• Analyze usage trends to improve the Services and user experience.
• Comply with legal obligations, including tax and regulatory reporting.

5. Sharing Your Personal Data

We may share your personal data with:

• Data Processors: Third-party service providers (e.g., payment processors, cloud hosting, analytics providers) acting on our behalf under GDPR-compliant data processing agreements.
• Blockchain Networks: Transaction data (e.g., wallet addresses, Reward details) is recorded on public blockchains, which are not controlled by us and are accessible to anyone.
• Legal Authorities: When required by law, such as for tax compliance, anti-money laundering, or in response to legal processes.
• Business Transfers: In the event of a merger, acquisition, or asset sale, your data may be transferred to a successor entity under GDPR safeguards.

We do not sell your personal data to third parties for marketing purposes.

6. International Data Transfers

The Services are hosted in the United States. If you are located in the EU/EEA, your personal data may be transferred to the U.S., which does not have an adequacy decision from the European Commission. We rely on the following safeguards under GDPR Article 46 to ensure lawful transfers:

• Standard Contractual Clauses (SCCs) approved by the European Commission with our U.S.-based service providers.
• Explicit consent for certain transfers, where applicable.

Contact us at privacy@cryptoplaystudio.com for copies of our SCCs or further details.

7. Your GDPR Rights

Under GDPR, you have the following rights regarding your personal data:

• Access (Article 15): Request a copy of your personal data.
• Rectification (Article 16): Request correction of inaccurate data.
• Erasure (Article 17): Request deletion of your data, subject to legal retention requirements (note: blockchain data cannot be erased due to its immutable nature).
• Restriction (Article 18): Request restriction of data processing under certain conditions.
• Data Portability (Article 20): Request your data in a structured, commonly used, and machine-readable format.
• Objection (Article 21): Object to processing based on legitimate interests or direct marketing.
• Withdraw Consent (Article 7(3)): Withdraw consent at any time, without affecting the lawfulness of prior processing.
• Complaint (Article 77): Lodge a complaint with an EU/EEA supervisory authority, such as the data protection authority in your country.

To exercise these rights, contact us at privacy@cryptoplaystudio.com. We will respond within one month, though this may be extended by two months for complex requests, as per GDPR Article 12(3).

8. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this policy or as required by law. For example:

• Account data is retained for the duration of your account or until you request deletion.
• Transaction data may be retained for tax or regulatory purposes (e.g., 7 years under U.S. tax law).
• Blockchain data (e.g., wallet addresses, Reward transactions) is permanently stored on public blockchains and cannot be deleted.

Upon deletion requests, we will erase personal data we control, subject to legal obligations, but cannot delete blockchain data due to its immutability.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including encryption, access controls, and secure servers, as required by GDPR Article 32. However, no system is completely secure, and we cannot guarantee the security of data transmitted over the internet or stored on public blockchains, which are beyond our control.

You are responsible for securing your cryptocurrency wallet, private keys, and account credentials. We are not liable for losses due to compromised wallets or unauthorized access.

10. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance functionality, analyze usage, and provide personalized content. Per GDPR, we obtain your consent for non-essential cookies via a cookie banner. You can manage your preferences through the banner or your browser settings. Essential cookies required for the Services’ functionality do not require consent.

11. Children’s Data

Our Services are not intended for children under 16 in the EU/EEA, as per GDPR Article 8. We do not knowingly collect personal data from children under 16 without verifiable parental consent. If we learn such data has been collected, we will delete it unless required by law. Contact us at privacy@cryptoplaystudio.com if you believe a child under 16 has provided personal data.

12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of material changes via email or a prominent notice on our website before they take effect, as required by GDPR Article 13(3). Continued use of the Services constitutes acceptance of the updated policy.

13. Contact Us

For questions, concerns, or to exercise your GDPR rights, contact us at:

PLAY TO EARN GAMES, LLC
2719 Hollywood Blvd, Hollywood, FL 33020
Email: privacy@cryptoplaystudio.com

You may also contact your local EU/EEA data protection authority for assistance.