Introduction

Welcome, and Thank you for your interest in Cointracts (“Cointracts” “we,” “us,” or “our”), which operates the ecosystem of websites and apps dedicated to the provision of gaming and education services (collectively and individually referenced as the “Platform”).

Cointracts collects personal information of users of its Platform and uses it to provide the different services and functionalities available on the Platform, to inform Platform users about content that might be relevant to them and to operate the Platform.

If you have any doubt or query, you can contact us through support@cointracts.com.

In this Privacy Policy, you will find information regarding the following:

1. Who is the controller of your personal data and whom to contact?
2. What information do we collect about you and how do we obtain it?
3. How do we use your personal data?
4. How do we store personal data and how are they secured?
5. For how long do we collect and use your information?
6. Who do we share your information with?
7. Where do we process your information?
8. What are your rights?
9. Modifications of Privacy Policy

1. WHO IS THE CONTROLLER OF YOUR PERSONAL DATA AND WHOM TO CONTACT?

The controller of personal data is Cointracts Prop FZ LLC with its registered office at registered in the Commercial Register maintained by the (hereinafter referred to as “we”, “our”, “our Company”, or “Controller”).

You can contact Cointracts Prop FZ LLC at or at support@cointracts.com regarding any questions and the exercise of rights relating to the processing of your personal data.

2. WHAT INFORMATION DO WE COLLECT ABOUT YOU AND HOW DO WE OBTAIN IT?

In this section, you can read general information about which of your personal data we collect and how we collect it. Detailed information on the purposes for which we process personal data is given in Section 3 of this Policy. All information on the basis of which we can directly or indirectly identify you or which is related to you is considered personal data.

We obtain most of the data we collect about you directly from you in connection with your use of our services. This includes, in particular:

Data that you provide to us yourself, especially when you register on the website, enter information into your user account, order services, participate in our events and projects, or when you communicate with us through customer support or social networks. These are identification and contact data, specifically the name, surname, telephone number, e‑mail address, postal address, date of birth, user name and password, and business identification number or tax registration number, if you are an entrepreneur; payment data, such as bank details; and other data, such as records of communication between you and our company or details of any warranty claims.

Data that we automatically collect when you use our services. These are data about your device (such as the IP address, device type, operating system, browser used, connection provider); website usage data (such as the date, time and duration of visit, a country from which you visit the website, website browsing history), and data on the use of services (such as the login and logout information, your account settings, the value of your fictitious capital, your account currency, business strategy).

3. HOW DO WE USE YOUR PERSONAL DATA?

Registration

Only users over the age of 18 can register, unless so permitted by the holder of the parental responsibility.

Cointracts offers you different ways to register:

” You can register by creating an account, for which we will request the information necessary for the login and contact information.

“You can register via designated social media accounts. In this case, Cointracts will access your social media username to authenticate you and, where permitted by you, access and process information about your social media account.

” You can connect your wallet as a way of registration. Wallets allow users to send and receive cryptocurrencies like bitcoin and ether, storing their passwords or keys. If you connect your wallet you will share with us your public address and will allow us to visualize your funds. We will never ask you to provide us access to your funds or to allow us to carry out any action regarding your funds other than visualization.

We use personal data for the following purposes:

• Registration and user account

In order to use the services, you must register on the website and create your account, and for this purpose we process your personal data.

Personal data: identification and contact data; we may also process your data related to the settings of your user account.

Legal ground for the processing: Processing is necessary for the performance of the contract, and the provision of these personal data is required, as we cannot register your user account without them.

• Provision of services and exercise of rights and obligations under the contract between us and the customer

In order to be able to provide you with our services, i.e. in particular to provide you with the relevant access, tools and support, and to carry out trades, we need to process your personal data. For this purpose, the following shall apply:

Personal data: Identification and contact data and, in the case of paid services, also payment data, data on the use of the services, data on the simulated trades and, if you decide to link your social networks accounts with the account on the website, also data from social networks.

Legal ground for the processing: Processing is necessary for the performance of the contract on the basis of which we provide our services, or on the basis of our legitimate interest. After we stop providing you with services, we process personal information for a limited period of time. Such processing is necessary for the purposes of exercising and protecting our rights based on our legitimate interests.

• Marketing communication about our services and products or about events in which we take part

If you are our current or past customer, we may from time to time send you marketing communications that relate to our services. We may also send you commercial communications to the extent to which you give us your consent. Each of the e-mails sent will be marked as a business communication and each of them will contain a link with the help of which you can easily unsubscribe from the business communications. For this purpose, the following shall apply:

Personal data: Identification and contact data.

Legal ground for the processing: If we have provided you with our services, we may from time to time send you marketing communications based on our legitimate interest, namely keeping in touch with our customers. If you give us your consent to process your data for marketing purposes, then we process your data on the basis thereof.

• Customer support and communication

If you use our customer support services, we will process your personal data. For this purpose, the following shall apply:

Personal data: Identification data, contact data, other data and data from social networks, if you contact us through social networks.

Legal ground for the processing: Processing is based on our legitimate interest, namely in maintaining customer satisfaction and supporting the use of our services.

• Improving services

If you use some of our services, we will process your personal data in order to develop, test and enhance the services and improve their security. For this purpose, the following shall apply:

Personal data: Identification and contact data, data about your device, website usage data, data on the use of the services, and data on the simulated trades.

Legal ground for the processing: Processing is based on our legitimate interest, namely in improving our services.

Cointracts uses this information to the extent necessary to provide users with the registration functionality, as so requested by them.

Please contact us through support@cointracts.com if you do not want any kind of personalization when you interact with the Platform.

4. HOW DO WE STORE PERSONAL DATA AND HOW ARE THEY SECURED?

We process your personal data in an encrypted database on computers and other devices. In order to ensure protection against unauthorised access or unauthorised alteration, disclosure or destruction of the data that we collect and process, we have adopted organisational and technical measures to secure them, which we strictly adhere to.

2.3. We use your personal information to operate the Platform

We use the personal information you have provided us or the personal information we have observed from you to operate the Platform. This includes the use of your information:

” To ensure network and information security and troubleshooting: we might use your information to ensure the Platform and related information systems are able to resist, at a given level of confidence, accidental events or unlawful or malicious actions that compromise the availability, authenticity, integrity and confidentiality of stored or transmitted personal data, and the security of the related services offered. This could, for example, include stopping denial of service attacks and damage to computer and electronic communication systems. We might also use your information (for instance, because you alert us or because we observe you are having troubles in performing and action within the Platform) to find bugs, errors or malfunctions so that we can fix them.

” To fight against and prevent fraudulent activities, or other harmful activities: if we detect activity that might be fraudulent, harmful or otherwise contrary to our rules and policies (especially, without limitation, this Privacy Policy, our Terms of Use ), we will use the information at our disposal to the extent available (e.g., information provided by you, data obtained from cookies, information found in public blockchains and public sources) to do the necessary research to determine whether someone might be committing fraud or acting in a way that can harm us, other users or third-parties. We will use this information to fight against the fraudulent and/or harmful activity, including by taking action as described in our Terms of Use.

” For the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

While we understand it is in our best interest to carry out the activities above, all of them are also a way to protect, defend, make stronger and ultimately grow our community. The success of our Platform as a tool to spread knowledge and connect people must be based in strong commitments to business quality and security. Only by providing the best service we can fulfill our mission and our community’s. We understand the activities above have an impact on users’ privacy and it is our commitment to limit that impact to the minimum by only using the information that is strictly necessary to successfully perform these activities. Please contact us through support@cointracts.com if you would like further information on why we think our interest in performing the above activities is aligned with our community’s interest and why, all in all, we understand our aggregate interest is greater than each individual impact these activities might have on privacy.

5. For how long do we collect and use your information?

Our commitment is to use your information for no longer than what is necessary to achieve the purposes explained.

When we use your information to provide you with the services and functionalities available on the Platform, we use your information for the time necessary to provide you with these services and functionalities. Where the information you provide is not strictly necessary to provide the service or functionality, it means that you are free to include this information (for instance, information to build your profile) or that we have obtained it with your previous consent (for instance, information obtained from cookies), and, therefore, you can choose whether and to what extent you want us to stop using this information.

If we see that your account and/or profile is inactive for a long period of time (after three years with no activity), we might contact you to see whether you want to keep your account and/or profile or whether it is better to delete it.

When we use your information to inform you about content that might be relevant for you, you can decide when we shall stop using it.

When we use your information to operate the Platform, we stop using it and delete it once we have completed the activity for which we are using the information. For instance, we will keep the information you provided us in relation to an error in the Platform until that error is fixed or before, if we think the information is no longer necessary to fix the error. When we use information to prevent or fight against fraudulent or harmful activity, we will keep the information for as long necessary to arrive at conclusions and delete it in case we find there is no wrongdoing.

 Where we find there has been a wrongdoing, we will keep the information for the time necessary to exercise or defence against legal claims.

Oftentimes, we are required by law to retain your personal information for a period of time before it can be permanently deleted from our systems. In these cases, we will make sure your information remains duly blocked, so it is only accessible to privileged personnel and public authorities.

6. Who do we share your information with?

We share your information with third parties when necessary to provide you with the services and functionalities you requested, when so consented by you or when necessary to comply with a legal obligation.

We generally share your information with the following third parties:

” Group affiliates: your information will be shared with other companies of the COINTRACTS group that are providing a service to COINTRACTS, under the instructions and responsibility of COINTRACTS.

” Partners: when an experience is co-hosted or jointly organized with a partner, we will share your information with them to the extent necessary to manage your participation, as per your request, or to comply with our commitments under the applicable terms and conditions.

” Advertising partners: when we have your consent, we will share your information with third parties with the purpose of providing you with advertising. For instance, if you consent to the placement of cookies, we will share a pseudonymous random identifier with Platform’s advertising partners’ so that we can show you ads about online courses or experiences in third-party websites.

” Public authorities: to comply with applicable legislation, governmental demands, a judicial procedure, court order, or legal process, such as in response to a court order or a subpoena, we may release information (including in response to public authorities to meet national security or law enforcement requirements). We may disclose your information if we believe it is necessary to investigate, prevent, or act in connection with potential policy violations, suspected fraud, situations involving potential threats to the safety of any person, or illegal activities, or as evidence in litigation in which we are involved.

” Service providers: we will share your information with third-party service providers that are providing a service to COINTRACTS, under the instructions and responsibility of COINTRACTS.

7. Where do we process your information?

COINTRACTS is located and the Platform is run from UAE.

We follow the standard set by European Union (“EU”) data protection rules and, therefore, when we share personal information of EU and UK users with service providers located outside the EU and UK  , we put in place appropriate contractual guarantees to ensure the use of your personal information takes place under a similar standard only.

8. What are your rights?

Depending on your location, your legal rights in relation to your personal information are different. As commented, we follow the standard set by EU data protection rules to have a uniform set of guidelines and rules to use information about our users, regardless on where they are located. This way we ensure we follow one of the most developed and user-friendly regimes in the world. When necessary, we will adapt to your local legislation to provide you with the rights it recognizes to you.

You have the following rights in respect to the use of your personal information:

” Right to access: you can request access to and a copy of your personal information. This permits you to request confirmation that we are processing your personal information and information about how we are using it.

” Right to rectification: you can request that we correct information that you believe is incorrect and complete information that you believe is missing, albeit we may need to verify the veracity of the new data provided by you.

” Right to erasure: you can that we erase or destroy any personal data we hold about you; however, we may not always be able to comply with your request if there is an ongoing service with you and we need your information to manage any pending obligations or if there are legal reasons preventing us from doing so.

” Right to object: you have the right to object to us using your information to inform you about content that we think might be relevant for you as well as for the activities to operate the Platform by directly contacting us through support@cointracts.com. In the latter case, we may demonstrate that we have compelling legitimate grounds to process your information.

” Right to restriction of processing: you have the right to limit our use of your information if you dispute its accuracy or you think we should not be using your information, for the time necessary to verify your claim.

” Right to data portability: you have the right to request the transfer of your profile information to you or to a third party. We will provide the information in a structured, commonly used, machine-readable format.

” Right to withdraw you consent: where you have freely provided your information and it not necessary for the provision of a service or functionality or a legal obligation, you can ask us to at any time to stop using this information.

9. Modifications of this Privacy Policy

Cointracts may modify this Privacy Policy for several reasons. For instance, this could happen if we needed to reflect any legal or regulatory changes, or to adapt to decisions by public authorities. Also, if we needed to reflect changes to the way we handle personal data or changes to the services and functionalities available on the Platform, or simply if we needed to make amendments to the wording of this Privacy Policy without altering its content or meaning.

Where these modifications significantly change the way we use your personal information, COINTRACTS will provide prior notice via a general notice in the Platform, unless COINTRACTS is legally obliged to make the modifications immediately or within a shorter term.

If you do not accept the way we process personal information at any given time, you are free to stop using the Platform and/or delete your account, where necessary, and exercise any of the abovementioned rights through support@cointracts.com.

The updated and previous versions of the Privacy Policy will be available at all times on the Platform.