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PRIVACY POLICY

Effective Date: September 2, 2025
Last Updated: September 2, 2025

TrixTri Limited (a company incorporated under the laws of the British Virgin Islands, Company Number: [To be assigned]) ("TrixTri," "we," "us," or "our") is committed to protecting the privacy and security of our users' personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our GameFi platform, including our website, mobile applications, smart contracts, and related services (collectively, the "Platform").

1. INFORMATION WE COLLECT

1.1 Information You Provide Directly

  • Account Information: Username, email address, wallet addresses, and profile information
  • Identity Verification: For compliance purposes, we may collect government-issued ID, proof of address, and other KYC (Know Your Customer) documentation
  • Transaction Data: Purchase history, NFT holdings, token transactions, and staking activities
  • Communications: Correspondence via email, support tickets, or community platforms
  • User Content: Forum posts, votes in governance proposals, and gameplay decisions

1.2 Information Collected Automatically

  • Blockchain Data: Public wallet addresses, transaction hashes, smart contract interactions
  • Device Information: IP address, browser type, operating system, device identifiers
  • Usage Data: Pages visited, features used, gameplay statistics, time spent on Platform
  • Cookies and Similar Technologies: Session cookies, analytics cookies, and local storage data
  • Performance Data: Error reports, load times, and system diagnostics

1.3 Information from Third Parties

  • Wallet Providers: Information from MetaMask, WalletConnect, or other Web3 wallets
  • Social Media: If you connect social accounts for authentication or sharing
  • Analytics Providers: Aggregated data about user behavior and demographics
  • Compliance Services: Identity verification and sanctions screening results

2. HOW WE USE YOUR INFORMATION

2.1 Platform Operations

  • Process transactions and manage your account
  • Facilitate NFT minting, trading, and burning mechanisms
  • Calculate and distribute staking rewards and governance tokens
  • Enable participation in gameplay challenges and competitions
  • Provide customer support and respond to inquiries

2.2 Security and Compliance

  • Detect and prevent fraud, scams, and unauthorized access
  • Comply with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations
  • Enforce our Terms of Service and community guidelines
  • Protect users from social engineering and phishing attempts
  • Maintain the integrity of our governance and voting systems

2.3 Improvements and Analytics

  • Analyze gameplay patterns to balance game mechanics
  • Improve user experience and platform features
  • Conduct research on GameFi economics and user behavior
  • Generate aggregated statistics about platform usage

3. LEGAL BASIS FOR PROCESSING (GDPR)

For users in the European Economic Area (EEA) and United Kingdom, we process personal data based on:

Legal BasisPurpose
Contract PerformanceAccount management, transaction processing, gameplay features
Legal ObligationsKYC/AML compliance, regulatory reporting, tax requirements
Legitimate InterestsPlatform security, fraud prevention, service improvements
ConsentMarketing communications, optional features, cookies

4. DATA SHARING AND DISCLOSURE

4.1 Service Providers

We share data with carefully selected third parties who assist in operating our Platform:

  • Cloud hosting providers (AWS, Google Cloud)
  • Blockchain infrastructure providers
  • Identity verification services
  • Analytics and monitoring tools
  • Customer support platforms

4.2 Legal and Regulatory

We may disclose information when required by:

  • Court orders, subpoenas, or legal processes
  • Regulatory authorities in applicable jurisdictions
  • Law enforcement agencies for criminal investigations
  • Tax authorities for reporting obligations

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, user data may be transferred to the acquiring entity, subject to the same privacy protections.

4.4 Public Blockchain Data

Important: Transactions on public blockchains are permanently visible. We cannot delete or modify blockchain records.

5. INTERNATIONAL DATA TRANSFERS

As a BVI-registered company operating globally, we transfer data across borders. We ensure appropriate safeguards through:

  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Adequacy decisions where applicable
  • Technical and organizational security measures
  • Data processing agreements with all third-party processors

6. DATA RETENTION

Data CategoryRetention Period
Account InformationDuration of account + 7 years
Transaction Records7 years (regulatory requirement)
KYC Documentation5 years after relationship ends
Support Communications3 years
Analytics Data2 years
Marketing PreferencesUntil withdrawn

7. YOUR RIGHTS AND CHOICES

7.1 Data Subject Rights (GDPR/CCPA)

Depending on your location, you may have the right to:

  • Access: Request a copy of your personal data
  • Rectification: Correct inaccurate or incomplete data
  • Erasure: Delete your data (subject to legal obligations)
  • Portability: Receive your data in a machine-readable format
  • Restriction: Limit processing of your data
  • Objection: Opt-out of certain processing activities
  • Automated Decision-Making: Request human review of automated decisions

7.2 Exercising Your Rights

To exercise your rights, contact us at: privacy@trixtri.game

We will respond within 30 days (or as required by applicable law).

8. SECURITY MEASURES

We implement industry-standard security measures including:

  • Encryption of data in transit (TLS 1.3) and at rest (AES-256)
  • Multi-signature wallets for treasury management
  • Regular security audits and penetration testing
  • Access controls and authentication mechanisms
  • Incident response and disaster recovery procedures
  • Employee training on data protection and security

9. CHILDREN'S PRIVACY

The Platform is not intended for users under 18 years of age. We do not knowingly collect personal information from minors. If we discover that a minor has provided us with personal information, we will delete such information immediately.

10. COOKIES AND TRACKING

10.1 Types of Cookies We Use

  • Essential Cookies: Required for Platform functionality
  • Analytics Cookies: Help us understand usage patterns
  • Preference Cookies: Remember your settings and choices
  • Marketing Cookies: Used for targeted advertising (with consent)

10.2 Managing Cookies

You can control cookies through your browser settings. Note that disabling certain cookies may impact Platform functionality.

11. THIRD-PARTY LINKS

Our Platform may contain links to third-party websites or services. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

12. UPDATES TO THIS POLICY

We may update this Privacy Policy periodically. Material changes will be notified via:

  • Email notification to registered users
  • Prominent notice on the Platform
  • Update to the "Last Updated" date

13. JURISDICTION-SPECIFIC PROVISIONS

13.1 California Residents (CCPA/CPRA)

California residents have additional rights including the right to know what personal information is collected, used, shared, or sold. We do not sell personal information.

13.2 European Economic Area (GDPR)

EEA residents may lodge complaints with their local supervisory authority if they believe their rights have been violated.

14. CONTACT INFORMATION

Data Controller: TrixTri Limited

Registered Address:
[Address to be inserted]
Road Town, Tortola
British Virgin Islands

Email: privacy@trixtri.game

Data Protection Officer: dpo@trixtri.game

For general inquiries: support@trixtri.game

For legal matters: legal@trixtri.game

© 2025 TrixTri Limited. All rights reserved. TrixTri is a registered trademark.

This Privacy Policy is governed by the laws of the British Virgin Islands.

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