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1. Foreword

CyLimit is a fantasy cycling game with officially licensed digital cards hosted as NFTs on the blockchain.

We respect your privacy and are committed to providing a secure environment for our Users. This privacy policy (“Policy”) is intended to provide you with important information about how and why your data may be collected and processed by CyLimit (“We” or “CyLimit”). Your data will be processed in accordance with applicable law, including the European Union’s General Data Protection Regulation (“GDPR”), U.S. federal and state law governing the protection of personal data, and any other applicable personal data protection laws (“Personal Data”). 

2. Data collected and purpose of processing

We collect and process a limited amount of Personal Data for specific and identified purposes, such as to enable you to access the Services, to make the Services easy and enjoyable to use, to improve your experience and to identify and prevent fraud. Whenever we collect your Personal Information, regardless of the purpose(s), we will always collect the minimum amount of information necessary to fulfill that purpose.

This section is intended to provide you with more information about the Personal Data we collect, the purposes for which we process Personal Data and the legal basis for each specific processing operation.

  • Account Information. CyLimit collects and processes Personal Information to enable you to create and access your User account. In order to manage your User account from creation to deletion, you must provide us with certain information about yourself (including your first name, last name, user name, email address, and for certain operations your cell phone number for identity verification purposes). You will also be able to save personal settings, such as your preferences and favorite teams or players, in your general user account and/or through your browser and terminal. In order to store them, CyLimit will associate your choices with your User account and potentially with the technical identifiers of your browser and/or device.
    • The legal basis for this processing is contractual. We need this data in order to create and maintain your User account, to enforce CyLimit’s General Terms and Conditions and any additional applicable contractual terms and conditions that you agreed to when creating your User account.
  • Website Usage. CyLimit collects and processes certain Personal Data to understand how Users interact with its Services and to improve their experience. This Data consists of various navigational information derived from Cookies or mobile technical identifiers (see Cookie Policy), some of which may include Personal Data.
    • The legal basis for this processing depends on your location and the applicable law. In countries where the use of cookies is conditional on prior consent from Users, CyLimit processes such Data on the basis of your consent. In other countries, CyLimit processes such Data on the basis of (i) its legitimate interest, in particular to understand how its Services are used by Users and to improve those Services where necessary, or (ii) your consent.
  • Access and use of the Services. CyLimit collects and processes your Personal Information to enable you to access and use its various Services, including to facilitate the purchase of a Trading Card, play the Game, or participate in our Refer a Friend or Partner Programs.
    • To purchase a Trading Card through auctions offered by CyLimit and/or to purchase, transfer, withdraw and/or redeem a Trading Card through the Marketplace, CyLimit collects your username, phone number, public wallet key or payment ID and has access to a portion of your credit card number (i.e., the last four digits of the credit card which we access through our payment service providers but do not collect or store directly).
    • To facilitate participation in a Championship, award prizes to winners, publish leaderboards, and more, CyLimit processes your username, phone number, public wallet key, and prize(s) you have won (if any). CyLimit may publish your username and prize(s) on its website as part of the tournament results leaderboard.
    • To enable participation in our affiliate or referral program, CyLimit collects and processes your email address, phone number, username and public wallet key.
    • The legal basis for this processing is contractual. We need this data in order to enforce the Terms and Conditions, and any additional applicable terms, that you agreed to when you signed up for your user account.
  • Compliance with Terms; Website and Account Security. CyLimit collects certain information about your device and browser (“user agent”), your browsing data on its site, including your IP address (from which information about your country/location state can be inferred), your account information (including your email address and phone number) and transaction details, in order to ensure the security of the Services and your User account, and to detect, prevent, investigate and/or identify any attempted violation of our Terms and Conditions or any other applicable terms, such as by malicious hacking. In the course of an investigation, CyLimit may take additional security measures, including, but not limited to, requesting additional supporting documentation and/or information, or suspending or canceling the relevant transaction in the event the transaction cannot be verified. Where payment fraud is proven after investigation, relevant Personal Data and other information relating to the facts of the case will be stored in CyLimit’s monitoring system and may be used for future verification.
    • The legal basis for this processing is the legitimate interest of CyLimit. CyLimit has a legitimate interest in detecting, preventing and investigating fraud and attempted fraud that may affect its Services in order to ensure fair play for all Users and to protect its Services and Users from possible credit card or other fraud.
  • User Requests and Communications. CyLimit collects and processes Personal Data such as your user name, contact information and the content of your message (to the extent that it may contain Personal Data about you or a third party) in the course of managing and following up on questions and/or requests you may submit via our Help Center or any other method.
  • The legal basis for this processing is contractual. User assistance and support is an integral part of the Services we provide, so we need this data to enforce the Terms and Conditions, and any applicable additional terms, that you have agreed to or may agree to when creating your User account and/or using the Services.

3. Blockchain technology and your data

  • NFT. Blockchain technology is at the heart of the Services that CyLimit provides. Our Trading Cards are based on this technology in the form of non-fungible tokens (“NFT”) issued by CyLimit and which ensure the authenticity, rarity and interoperability of your Trading Cards.
  • Your Data. Your public wallet key and information about your purchases, transfers, withdrawals, and Trading Card exchanges are stored on our AWS servers, by Starkware, which provides the second tier described above, and by our data availability committee, whose members safeguard this information and are subject to strict confidentiality obligations. No personal data of our Users is stored by CyLimit on the public Ethereum blockchain. However, please note that if you remove your funds or a Trading Card from the CyLimit platform (e.g., to transfer them to another service or to another external wallet), this transfer will involve the storage of information related to that transfer on a public blockchain. All transfers to external wallets are subject to the privacy policy and/or terms of service of the relevant third-party service, so please be sure to review the privacy policies and practices of the relevant third parties before making such a transfer. As stated in our Terms and Conditions, CyLimit will not be held responsible for any third party content or service and disclaims any liability for any services provided to a user by a third party service provider.
  • The legal basis for this processing is contractual. Blockchain is at the heart of our services. These technologies allow CyLimit to ensure the authenticity, rarity and interoperability of your Trading Cards.

4. Data retention

  • User Account Information. CyLimit will retain your Personal Data until your account is closed. However, where required or permitted by applicable law, if CyLimit is required to retain certain Personal Data beyond the date of termination of your account, then the applicable maximum retention period will apply in accordance with applicable statutory limitation periods. This period will not exceed the period for which the Company is legally required to retain the Data.
  • Use of the Website. Personal Data processed by or on behalf of CyLimit for the purpose of analysis or other studies or analyses will not be retained by CyLimit after such studies have been completed and the relevant reports, results, statistics and/or overviews have been produced.
  • Access to the Services. Personal Data processed for the use of the Services will only be retained for fifteen (15) months from the date of the relevant activity.
  • Blockchain Technology. Personal Data processed and stored on a blockchain in connection with your transactions on CyLimit will be stored immutable. 
  • Compliance; Website and Account Security. Personal Data processed for fraud prevention will be retained for three (3) years after the relevant data has been included in an alert list. Personal Data processed for security purposes will be retained for five (5) years after the last login to the account or the last suspicious activity.
  • User Requests and Communications. For the purpose of handling your questions and/or requests, CyLimit will retain your Personal Data for a maximum of three (3) years from the last contact initiated by you.

Notwithstanding the foregoing, CyLimit may retain certain Personal Data for a longer period of time pursuant to its legitimate interests and applicable legal obligations. When the relevant retention period expires, CyLimit will delete your Personal Data or apply appropriate measures to the relevant data to ensure that you can no longer be identified.

If CyLimit concludes that it is not necessary to retain your Personal Data in its active database, it will archive the relevant Data. For all active and archived Data, CyLimit will ensure that access to the relevant Personal Data is limited to a limited number of individuals with a genuine need to access it.

5. Your Rights

Most applicable data protection laws (including the GDPR, and laws in certain U.S. states such as the California Consumer Privacy Act) provide individuals with rights in relation to their Personal Data and the manner in which that Data is processed. The section below is intended to inform you of the rights you have in relation to the processing of your Personal Data. Please note that all requests made under this section will be processed in accordance with applicable European laws (including the GDPR), regardless of your location or country of residence. However, our responses may be tailored to comply with the requirements of any applicable local laws.

You have the right to access, correct, move, and delete your Personal Data and a right to restrict the way your Data is processed. You also have the right to instruct us as to how your Personal Data should be handled after your death.

Requests

To exercise your rights or ask us a question about CyLimit’s data privacy practices, you may make a request by email to [email protected]

CyLimit will endeavor to respond to your request or inquiry as soon as possible, and no later than one (1) month from receipt of the request. For complex requests, we reserve the right to extend this period to three (3) months.

Individuals located in France may also submit a complaint to the Commission Nationale Informatique et Libert├ęs (“CNIL”). Individuals located in another Member State of the European Union may submit a request to the competent data protection authority in their country of residence.

Deletion of User Account

If you wish to request deletion of your Personal Data, you may use the method described above or simply request deletion of your User account via your User account settings as described in the CyLimit Terms and Conditions.

Deleting your account will result in the irreversible deletion of the Personal Data associated with the account. In order to ensure that your rights are respected without altering the history and traceability of each Trading Card you owned, the username associated with the ownership of those Trading Cards will be pseudonymized and replaced with a random series of alphanumeric characters.

It is essential that you back up all Trading Cards and crypto-currencies stored on your Wallet to an external wallet prior to any deletion request. Any Trading Cards and/or crypto-currencies stored in your Wallet that have not been transferred out of your account by the date of deletion will be permanently unrecoverable. CyLimit will not be responsible for the permanent loss of any Trading Cards and/or crypto-currency that was not backed up prior to a deletion request.

Protecting your Personal Data and complying with the applicable legal framework for data protection are both priorities for CyLimit and we need your help to achieve this. By agreeing to this policy, you agree to keep your Personal Information current on CyLimit and to provide only accurate and up-to-date Personal Information. In addition, if you send us information that would allow us to identify, directly or indirectly, other individuals, you represent and warrant that, prior to sharing such information, this Policy has been communicated to such other individuals and, to the extent applicable, that such individuals have consented to the processing of their Personal Data.

6. Cookies

When you browse our Website, cookies are deposited on your terminal, either directly or after having obtained your consent when required by the regulations on cookies.

Cookies are pieces of information deposited on the terminal equipment of the Internet user by the server of the visited website. They are used by a website to send information to the user’s browser and allow the browser to send information back to the originating website (for example, a session ID or language choice).

In theory, only the sender of a cookie can read or modify the information it contains.

There are different types of cookies:

session cookies that disappear as soon as you leave the website;

permanent cookies, which remain on your terminal until their lifetime expires or until you delete them using your browser’s functions.

You are informed that, during your visits to the Website, cookies may be installed on your terminal equipment. To learn more about the use of cookies on our Website, please consult the cookie policy here: CyLimit Cookie Policy.

7. Security

CyLimit has implemented and maintains measures to protect the confidentiality, security, and integrity of your User account and Personal Data from unauthorized access and disclosure, alteration, damage, accidental loss or destruction, and other unauthorized processing or disclosure.

We recommend that you follow best security practices, including storing your account information securely and not sharing your account information. Please note that our backup services will not back up your data to your personal, local storage or drive; we recommend that you use a secondary backup source and/or other best practices for data preservation. In addition, we recommend that you enable two-factor authentication, choose a strong password and/or use a password manager for all password-protected features and for your User account itself.

8. Updates to this Privacy Policy

CyLimit reserves the right to change this policy as necessary, as the Service evolves or as required by applicable law. You will be notified of any material changes to the policy. When you use the Services, you are deemed to have agreed to the terms of the Policy, as posted and updated on our Website.

9. Jurisdiction and Applicable Law

This Policy shall be governed by and construed in accordance with French and European law. However, if you are a consumer and a resident of a Member State of the European Union, you have the benefit of the mandatory provisions and rights recognized by the laws of your country of residence. As such, nothing in this Policy affects your rights as a consumer to rely on the mandatory provisions and rights granted to you by your local law.

Where permitted or required by applicable law, you agree that the courts of France shall have exclusive jurisdiction. However, if you are a consumer and a resident of any other member of the European Union, you and CyLimit may also bring proceedings in that country.