Skiller.Zone™ — Privacy Policy

Last Updated: September 3, 2026 Status: Working draft — requires review by qualified legal counsel before publication, particularly regarding applicability of GDPR/LGPD/other regional frameworks to your target markets.

[Skiller.Zone™ Operating Entity — legal name pending], a company to be incorporated under the laws of the Republic of Seychelles (registration number: pending) ("Skiller.Zone™," "we," "us," "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Skiller.Zone™ platform, including the website and Telegram Mini App (the "Platform").

1. Information We Collect

1.1. Information You Provide

• Account creation: name/nickname, email address, or Telegram identity data (initData) for Mini App users.
• Identity verification (KYC) — baseline tier: for MVP, Skiller.Zone™ collects a lighter verification set at registration (e.g., email and/or phone confirmation). We do not require full identity documents at signup.
• Identity verification (KYC) — elevated tier: Skiller.Zone™ reserves the right to request additional information — full legal name, date of birth, phone number, physical address, and/or a government-issued identity document — at any time our risk systems flag an account, transaction, or withdrawal for elevated review (see the Antifraud/Withdrawal risk model referenced in our Terms of Use). We will explain why elevated verification is being requested.
• Transactions: payment method details, wallet addresses, deposit and withdrawal history.
• Platform use: in-game platform tags ("gamertags"), match preferences, match history, and content of in-platform communications (see Section 2 for how communications are handled).
• Support requests: any information you provide when contacting support.

1.2. Information Collected Automatically

• Device information (browser type, operating system, device identifiers), including device fingerprinting used specifically for fraud- and collusion-prevention purposes.
• Usage data (pages/screens visited, features used, click patterns).
• Network information (IP address, approximate geographic location, ISP) — used among other things for jurisdictional geoblocking.
• Cookies and similar technologies (see our Cookie Policy).

1.3. Information from Third Parties

• Authentication providers (e.g., Telegram, Google, if applicable).
• Payment processors and fiat-to-crypto on-ramp aggregators (including 0xProcessing and similar providers): transaction status and verification results.
• KYC/AML verification providers.
• Blockchain address-screening vendors, used to check withdrawal destination addresses against sanctions lists and known illicit-activity databases.
• Analytics providers.

2. In-Platform Communications and Monitoring

2.1. Skiller.Zone™ provides several messaging features: pre-match waiting-room chat (tied to a unique Match ID, retained 72 hours), direct player-to-player messaging, and language-segmented live lobby chat (retained 72 hours).

2.2. Skiller.Zone™ does not directly or intentionally read every conversation on the Platform. However, Skiller.Zone™ performs periodic manual review and automated scanning — including through AI-assisted tools — of in-platform communications, for the specific purposes of detecting: (a) potential scams or fraud; (b) threats, harassment, or abusive language; and (c) advertising of third-party or competing services. Skiller.Zone™ reserves the right to issue strikes, suspensions, or bans based on violations identified through this process, consistent with the Terms of Use and Game Rules.

2.3. Legal basis: this monitoring is carried out on the basis of Skiller.Zone™'s legitimate interest in platform integrity, user safety, and fraud prevention.

2.4. Where a pre-match or lobby chat log becomes part of the evidentiary record for an active dispute, it is retained beyond the standard 72-hour window until the dispute (including any appeal) is resolved.

2.5. Users may block messages from another user at any time. Blocking does not remove Skiller.Zone™'s ability to access message logs for moderation, dispute resolution, or legal compliance purposes as described in this Policy.

3. How We Use Your Information

4. Automated Decision-Making

4.1. Skiller.Zone™ uses an automated risk-scoring system to evaluate withdrawal requests in real time (see Terms of Use, Section 5, and the Antifraud/Withdrawal model). This system considers factors such as account age, match/dispute history, device and network signals, deposit/withdrawal velocity, and destination-address screening results, to determine whether a withdrawal is processed instantly, subject to a short step-up check, or held for manual review.

4.2. If an automated decision results in your withdrawal being held for manual review, you may request human review of that decision by contacting support.

5. How We Share Your Information

We do not sell your personal information. We share it with:

• Service providers: payment processors and on-ramp aggregators (e.g., 0xProcessing), KYC/AML verification providers, blockchain address-screening vendors, cloud hosting, analytics, and email service providers.
• Other users: your nickname, match history, win/loss record, Fair Play Score/Completion Rate, and (where enabled) country flag are visible to other users. Your real name, contact details, and payment information are never shown to other users.
• Legal requirements: where required by law or a valid request from a competent authority, including for AML/CFT compliance.
• Business transfers: in connection with a merger, acquisition, or asset sale.
• With your consent: for any other disclosed purpose.

6. Data Security

We use industry-standard measures including encryption in transit (TLS/SSL), access controls, and regular security review. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

7. Data Retention

7.1. Account and transaction data is retained for as long as the account is active, and for five (5) years thereafter, to meet financial recordkeeping, AML, dispute-resolution, and fraud-prevention obligations, unless a longer period is required by applicable law in a specific jurisdiction.

7.2. Pre-match and live-lobby chat logs are retained for 72 hours, except where extended per Section 2.4 (active dispute evidence).

7.3. Direct player-to-player messages are retained under the standard account data retention schedule above, for moderation, dispute-resolution, and safety purposes.

8. Your Rights

Depending on your jurisdiction, you may have rights to access, correct, delete, or port your personal information, to object to or restrict certain processing, and to withdraw consent where processing is consent-based. To exercise these rights, contact us at [support contact to be added]. We aim to respond within 30 days, subject to legal retention obligations described in Section 7.

9. International Data Transfers

Your information may be processed in countries other than your country of residence, including the Republic of Seychelles and the jurisdictions of our service providers. We take reasonable steps to ensure appropriate safeguards where data is transferred internationally.

10. Children's Privacy

The Platform is not intended for individuals under 18 (or the age of majority in their jurisdiction). We do not knowingly collect information from minors; if we become aware that we have, we will delete it promptly.

11. Third-Party Links

The Platform may link to third-party sites or services (including the supported sports simulator title's own platforms). We are not responsible for their privacy practices.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be posted with an updated "Last Updated" date.

13. Contact

Support contact: [to be added]