Summary — we only ask for your email

• Collected: a single email address
• Not collected: real name, national ID, date of birth, phone number, address, government ID, bank account, card information
• Deposits / withdrawals: only USDT (TRC-20) and TRX wallet addresses on the TRON blockchain are used (these are not personal information)
• No KYC: registration and use are possible with just an email — no identity verification process

1. Information We Collect

The Company collects only the following information and does not collect any other personal data.

• Email address — for registration, login, and account identification
• External authentication identifier (optional) — when logging in via OAuth (e.g. Google), the account ID and email issued by that provider

2. Information Generated and Recorded Automatically

The following information is generated and recorded automatically by the system in the course of operating the Service. It does not directly identify an individual but is stored in association with the account.

• Wallet addresses: TRON (TRC-20) deposit addresses derived per member — public information on the blockchain
• Transaction history: deposit / withdrawal transaction hashes, betting and settlement records, comp accrual and claim records
• Access logs: IP address, access time, User-Agent, cookie ID — for fraud prevention and debugging

3. Purposes of Use

• Member identification and login session maintenance
• Processing of deposits, withdrawals, betting, and settlement
• Operation of comp / VIP / referral reward programs
• Notification of important matters (changes to terms, security incidents, etc.)
• Monitoring of fraudulent transactions and suspected money laundering

4. Retention Period

• Email and account information: until the member withdraws. Upon withdrawal, the data is deleted or de-identified immediately.
• Transaction records (deposits, withdrawals, betting): 5 years for operational and accounting purposes
• Access logs and IP addresses: 3 months
• If retention is required for legal or fraud-investigation reasons, the data is stored separately for the required period.

5. Provision to Third Parties

The Company does not sell or otherwise provide member information to outside parties. The following are exceptions.

• When the member has given prior consent
• When investigative or supervisory authorities request information through lawful procedures
• When necessary to protect legitimate interests, such as preventing money laundering and investigating fraud

6. Outsourced Processing

For service operation, certain processing tasks are outsourced to the following parties.

• Game content providers — betting and settlement processing. Only the internal member identifier is shared; email is not transmitted.
• OAuth providers (Google etc.) — login authentication. Only information for which the member has consented directly with the provider is received.
• Infrastructure providers (AWS, Cloudflare etc.) — server hosting and DDoS protection. Only traffic metadata is processed.

7. Member Rights

• You may request access to, correction of, deletion of, or suspension of processing of your information (email, transaction records).
• You may withdraw consent by terminating your membership. (Items subject to a legal retention obligation will be kept for the statutory period.)
• Rights can be exercised through your My Page or by contacting customer support.

8. Cookies and Tracking Technologies

Cookies and similar technologies are used to maintain login sessions and to block fraudulent access. They are not used for advertising or marketing tracking. You can block cookies in your browser settings, but some functions (e.g. staying logged in) may be limited.

9. Security Measures

• Encryption of transport channels with HTTPS / TLS
• Encrypted storage of session tokens
• Two-factor authentication (TOTP) and IP allowlisting for administrator accounts
• Multi-step review of withdrawal transactions and fraud monitoring
• Isolated storage of wallet private keys with minimized access privileges

10. Inquiries and Policy Changes

For privacy-related inquiries, please contact customer support or the Support channel within the site. If this policy is changed, the effective date and reason will be announced in advance.