This Privacy Notice explains how Trench Games and its affiliates (collectively, "Trench Games", "we", "us", or "our") handle your information in connection with our Sites and the Trench Games Platform (together, the "Services"). It also outlines your rights and choices regarding your data.

Please review this Privacy Notice carefully to understand our practices. If you do not agree with our policies, please do not use the Trench Games Platform. By accessing or using the Trench Games Platform, you acknowledge and accept the terms of this Privacy Notice.

We may update this Privacy Notice as laws, regulations, or our practices evolve. If we make changes that significantly affect your privacy rights, we will take appropriate steps to notify you, depending on the nature of the changes. If you disagree with any updates, you should stop using the Trench Games Platform.

Our Services are not intended for individuals under 18, and we do not knowingly collect personal data from minors. If you are a parent or guardian and become aware that your child has provided us with information, please contact us so we can remove it as soon as possible.

Personal Data Controller

"Personal Data" refers to information that can be linked to a specific person and used to identify them. This does not include data that has been aggregated or anonymized so that individuals cannot be identified. Any mention of "Personal Data" in this Notice includes, but is not limited to, the definition in the Data Protection Act 2018.

A Personal Data controller is an individual or organization that determines the purposes and means of processing personal data, including instructing others to process, use, transfer, or disclose data on their behalf.

Types of Personal Data We Collect

The types of personal data we may collect from you or third parties depend on how you interact with us and may include:

• Financial details such as your wallet addresses;
• Transaction data, including wallet addresses of senders and recipients, activities on the Trench Games Platform, your inquiries, and our responses;
• Usage information, such as your IP address, country of origin, browser or operating system features, and how you use the Trench Games Platform;
• Other personal, commercial, or identification information that we may require to comply with anti-money laundering laws and regulations.

We may also obtain personal data about you from third parties or publicly available sources.

We collect this information when you provide it directly on the Trench Games Platform or when you use our services. We may also collect data from third parties or public sources as described above.

Unless otherwise specified, all personal data requested by us is required, and failure to provide it may prevent you from accessing or using the Trench Games Platform. Where the Platform states that some data is optional, you are free not to provide it without affecting your use of the Platform. If you are unsure which data is required, please contact us for clarification.

Information Collected Automatically

When you visit the Trench Games Platform, we may automatically gather certain information about your device, such as your web browser, IP address, domain name, device identifiers, login details, browser type and version, timezone, browser plugins, operating system, location, and cookies. We may also collect information about the pages or services you view, referring websites or search terms, and your interactions with the Platform.

Cookies & Similar Technologies

We use cookies (small text files stored on your device) and similar technologies ("Cookies") to provide certain features and collect data. This section explains how we use Cookies and how you can control them.

How We Use Cookies

Cookies help us track how you use the Trench Games Platform, deliver updates, and enable account authentication based on your browsing history and previous visits.

We do not combine or link cookie data with third-party data for targeted advertising or share user/device data with data brokers.

Types of Cookies

We use both session cookies (which expire when you close your browser) and persistent cookies (which remain until deleted). Cookies on our Platform fall into these categories:

• Strictly Necessary: Essential for the Platform to function, including authentication and authorization.
• Functionality: Enable technical performance and remember your choices, such as preferences and sign-in credentials.
• Performance/Analytical: Help us understand how you navigate the Platform and what we can improve.
• Targeting: Deliver relevant information to your device based on previous visits. Some are operated by third parties with our permission to identify effective advertising sources.

Managing Cookies

You can control, block, or restrict cookies through your browser settings. Each browser and device is different, so check your browser’s Help section for details. For more information, visit https://www.allaboutcookies.org.

Disabling cookies may affect the functionality of the Platform. We are not responsible for any issues caused by your cookie settings.

Google Analytics

We may use Google Analytics to analyze Platform usage. Google Analytics uses cookies to generate reports about site usage. Google stores this information.

If you do not want your visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details, visit the Google Analytics opt-out page.

How We Process Data

Processing Methods

We use appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of your data.

Personal data is processed using computers and IT tools, following procedures related to the purposes described. Data may be accessible to you, certain staff (administration, legal, system administration), or external parties (such as technical service providers, hosting providers, or IT companies) appointed as Data Processors. You may request a list of these parties at any time.

Legal Basis for Processing

We may process your personal data if one of the following applies:

• You have given consent for specific purposes. In some cases, we may process data until you opt out, without relying on consent or other legal bases.
• Processing is necessary to perform an agreement with you or for pre-contractual obligations.
• Processing is required to comply with a legal obligation.
• Processing is related to a task carried out in the public interest or in the exercise of official authority vested in us.
• Processing is necessary for our legitimate interests or those of a third party.

How We Use Personal Data

We use your data to:

• Provide the Platform and customer support you request;
• Process transactions and send notifications about your activity on the Platform;
• Detect malicious or fraudulent activity;
• Monitor and analyze your behavior ("Analytics");
• Beta test features or the Platform itself;
• Contact you;
• Display content from external platforms;
• Handle productivity-related activities;
• Provide social features;
• Optimize traffic and Platform performance;
• Register you as a user and authenticate your credentials;
• Comply with legal obligations and respond to enforcement requests;
• Protect the rights and interests of Trench Games, its affiliates, users, and third parties;
• Monitor infrastructure;
• Enable interaction with external social networks and platforms;
• Support location-based interactions;
• Manage tags for analytics and tracking;
• Facilitate traffic optimization and distribution.

How We Share Personal Data

We may share your personal data with service providers and vendors to help us deliver the Platform. We do not share your data with third parties without your consent, except as described in this Notice or as required or permitted by law. We may share data within our group and with affiliates for purposes consistent with this Notice.

We may share your data with third-party companies and individuals who provide services on our behalf or help us operate the Platform. These third parties may use your data only as directed by us and in accordance with this Notice, and are prohibited from using or disclosing your information for other purposes. We may also share your data for compliance purposes.

In the event of a business transaction (such as a merger, acquisition, reorganization, or sale of assets), we may transfer or share your data as part of that transaction.

Data Retention

We retain your personal data as long as necessary to fulfill the purposes for which it was collected, including legal, regulatory, accounting, or reporting requirements. Retention is based on the amount, nature, and sensitivity of the data, potential risks, processing purposes, and legal requirements.

Personal data collected for contract performance is retained until the contract is fully performed. Data collected for legitimate interests is kept as long as needed for those purposes.

We may retain data longer if you have given consent, as long as consent is not withdrawn. We may also be required to retain data for legal obligations or by order of an authority.

Once the retention period ends, data will be deleted or, where allowed, de-identified. After this, rights such as access, erasure, rectification, and portability may not be enforceable.

Some data may not be deletable or de-identifiable; see the "Blockchain Transactions" section below.

Privacy Technology Practices

Links to Third-Party Sites

The Platform may contain links to third-party websites, apps, or services. These links do not imply endorsement or affiliation. We do not control third-party sites and are not responsible for their actions. We encourage you to review their privacy policies.

Data Security

We take the security of your data seriously and use administrative, technical, and physical safeguards to protect it. You are also responsible for keeping your personal security information safe.

While we strive to protect your data, transmission over the internet is not completely secure. Any transmission is at your own risk.

Blockchain Transactions

Your use of digital assets may be recorded on a public blockchain, such as when trades are settled. Public blockchains are distributed ledgers that immutably record transactions. These ledgers are open to analysis, which can sometimes lead to re-identification of individuals, especially when combined with other data.

Because blockchains are decentralized and not controlled by us, we cannot erase, modify, or alter data recorded on them.

International Data Transfers and Your Rights

Trench Games is the data controller for relevant data protection laws. As a global company, your data may be transferred outside your country for the purposes described. Any such transfer will comply with applicable law and be protected by appropriate agreements. By using the Platform, you understand your data may be processed in the United States and outside the EEA and UK.

Residents of the EEA and UK have certain rights regarding their data, including:

• The right to confirm what data we process about you.
• The right to correct inaccurate data.
• The right to request deletion of your data, subject to legal exceptions.
• The right to restrict certain processing, unless necessary for a contract or service.
• The right to receive your data in a structured, machine-readable format.
• The right to object to processing, including automated decision-making and profiling.
• The right to withdraw consent where previously given.

You are generally entitled to access the data we hold about you. If you request access, we will provide it unless there are legal or administrative reasons to deny it. We may charge a reasonable fee for access, but will explain any refusal if required by law.

Complaints: If you believe we have not respected your privacy or this Notice, please contact Support. We will investigate and notify you of the outcome.

General

To exercise your rights or contact us about your data, please reach out to Support with enough information to identify you and describe your request. Any data collected for verification will be used only for that purpose.

If you are concerned about our compliance with your legal rights or privacy laws, you may contact us or your local data protection authority.