Privacy Policy – Faylotto

Last Updated: June 10, 2025

1. Introduction

Faylotto Decentralized Betting Web3 Social ("We," "Faylotto," or "the Platform") is a decentralized betting platform built on Web3 technology, utilizing smart contracts on blockchain networks such as EVM multi chain. This Privacy Policy explains in detail how we collect, use, store, manage, and protect Users' personal data in accordance with global privacy standards, including the European Union’s General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and the principles outlined in the TRIPS Agreement and the Berne Convention.

By accessing or using the Platform, you agree to the data practices described in this policy. If you do not agree, please discontinue use of the Platform immediately.

2. Scope and Definitions

2.1. Scope

This policy applies to all Services provided by Faylotto, including the website, application, smart contracts, and Web3 social interactions. It does not cover data collected by third parties that are not under our control (e.g., public blockchain networks).

2.2. Definitions

Personal Data: Information that can identify an individual, such as name, email, or blockchain wallet address.
On-Chain Data: Information recorded on a public blockchain (e.g., transactions on Base Sepolia), which is transparent and immutable.
User: Any individual or entity who accesses or uses the Platform.
Services: The Platform’s features and functionalities, including decentralized betting, social interaction, and token holder analytics.

3. Types of Data Collected

We collect data in the following categories:

Data Category	Examples	Purpose
Identity Data	Name, email address, user ID	Account registration, communication
Web3 Wallet Data	Public wallet address, transaction history	Betting processes, reward distribution
Technical Data	IP address, browser type, cookies	Analytics, security, personalization
Usage Data	Betting history, social interactions	Service improvements, performance analysis
On-Chain Data	Token transactions, smart contract events	Transparency, reporting

4. Data Collection Methods

Data is collected through the following means:

Direct Interaction: When Users register, fill out forms, or participate in betting activities.
Automated Technologies: Cookies, tracking pixels, and server logs for analytics and security.
Public Blockchain: Transaction data from smart contracts on Base Sepolia, which is publicly accessible and automatically collected.
Third Parties: Service providers such as Google Analytics, advertising partners, or blockchain nodes.

5. Purpose of Data Use

We use data for the following purposes, based on legal grounds under GDPR (where applicable):

Service Delivery: To process bets, manage rewards, and display token holder lists (Legal Basis: Contract performance).
Platform Improvement: To analyze usage patterns for technical optimization and user experience (Legal Basis: Legitimate interest).
Marketing: To send updates or targeted ads, if you provide consent (Legal Basis: Consent).
Legal Compliance: To comply with anti-money laundering (AML) regulations, when required (Legal Basis: Legal obligation).
Security: To detect and prevent fraud or cyberattacks (Legal Basis: Legitimate interest).

6. Data Sharing and Disclosure

6.1. Third Parties

We may share data with:

Service Providers: Analytics vendors (e.g., Google Analytics), cloud providers, or blockchain partners for Platform operations.
Advertising Partners: Third parties for delivering personalized ads (if applicable).
Legal Authorities: When required by law, such as for AML investigations or court orders.
Public Blockchain: Transaction data on Base Sepolia is public and accessible by anyone.

6.2. No Sale of Personal Data

We do not sell your personal data to third parties for commercial purposes, in accordance with CCPA and GDPR.

7. Data Storage and Security

7.1. Storage

Personal data is stored on secure servers for as long as necessary for the purposes outlined, or as required by law. On-chain data on the blockchain is permanent and cannot be deleted.

7.2. Security

We implement industry-standard security measures, including:

Data encryption in transit (TLS/SSL) and at rest.
Role-based access controls to limit internal access.
Real-time monitoring for cyber threats.

However, no system is completely secure, and we cannot guarantee absolute security—particularly for on-chain data, which is publicly accessible.

8. User Rights

Under the GDPR, CCPA, and other global privacy laws, you have the following rights:

Right to Access: Request a copy of the personal data we hold about you.
Right to Rectify: Request corrections to inaccurate data.
Right to Erasure: Request deletion of personal data (excluding on-chain data, which cannot be erased).
Right to Restrict: Limit the processing of your data for specific purposes.
Right to Data Portability: Receive your data in a structured format for transfer.
Right to Object: Object to processing for direct marketing or legitimate interest purposes.

To exercise these rights, please send your request to support@faylotto.xyz. We will respond within 30 days (or 45 days under CCPA if an extension is needed).

9. International Data Transfers

Your data may be processed or stored in jurisdictions outside your country of residence, including on global cloud servers. We ensure that data transfers comply with GDPR Standard Contractual Clauses or other lawful mechanisms, such as the Privacy Shield (where applicable). On-chain blockchain data is not subject to transfer restrictions due to its decentralized nature.

10. Policy Updates

We may update this Privacy Policy to reflect changes in law, technology, or our operations. Updates will be published on the Platform, and Users will be notified via email or notification for material changes. Continued use of the Platform after such updates constitutes your acceptance.