Privacy Policy

Effective Date: Jan 1, 2025 | Rev. 2.4.0

This Privacy Policy ("Policy") governs the collection, use, and disclosure of personal information by Gin Rummy Duels. By accessing or using the Platform, you acknowledge that you have read, understood, and agree to be bound by this Policy.Effective Date: January 2025 · Version 1.2

1.0 Data Controller

The Data Controller for the purposes of this Policy is the operator of Gin Rummy Duels. For all data-related inquiries, including exercising your rights under GDPR, please contact: support@ginrummyduels.com.

2.0 Information We Collect

Identity & Verification Data: Unique cryptographic proof of personhood, blockchain wallet address, age verification timestamp. Profile Data: Player display name (optional, chosen by you), profile picture URL (sourced from the verifying identity app if provided). Technical Data: IP address, device identifiers, browser type, session tokens, and game state. Usage Data: Match history, rankings, entry fees paid, prizes received, and general platform interactions.

3.0 Identity Protocol & Zero-Knowledge Verification

We use a verified identity protocol exclusively for Proof of Personhood — to verify that each player is a unique, real human being. We do NOT store, access, or process any biometric data. All biometric verification occurs entirely on the protocol provider's infrastructure and is transmitted to us only as a zero-knowledge cryptographic proof. The identifier we store is a one-way cryptographic hash that cannot be reversed to reveal your real-world identity or any biometric information.

4.0 Legal Basis for Processing

We process your personal data under the following legal bases: (1) Contractual Necessity — to provide the gaming service, manage accounts, and process transactions; (2) Legitimate Interest — to prevent fraud, enforce fair play, and maintain platform security; (3) Explicit Consent — for optional features and any data processing not strictly necessary for the service; (4) Legal Obligation — to comply with applicable anti-money laundering (AML) regulations and gaming laws. You may withdraw consent for non-essential processing at any time by contacting us at support@ginrummyduels.com.

5.0 Third-Party Services

We engage professional third-party service providers to assist in operating the Platform, including: (1) database hosting and authentication infrastructure providers (GDPR-compliant, hosted within the EEA); (2) blockchain infrastructure and identity verification providers; (3) network node access and transaction monitoring providers; (4) transactional email and communication service providers. Each provider is contractually obligated to maintain data security and to use your information exclusively for the purpose of providing services to us.

6.0 Data Storage & Local Preferences

Your game data and account information are stored on secure cloud servers. Certain local preferences, such as sound settings, are stored in your browser's localStorage and are never transmitted to our servers. We do not use third-party tracking cookies. Any session cookies used are strictly necessary for authentication and expire when you close the application.

7.0 Data Retention

Active account data is retained for the duration of your account activity. Match history is retained indefinitely to preserve ranking integrity and leaderboard accuracy. Data retained for legal compliance purposes (e.g., financial transactions) is retained for a minimum of 7 years as required by applicable law. Blockchain transaction data is immutable and permanently stored on-chain beyond our control.

8.0 Data Security

We implement industry-standard security measures including: TLS/SSL encryption in transit, encrypted storage for sensitive fields, role-based access controls, and regular security monitoring. We perform periodic security reviews. Despite these efforts, no system is 100% secure. If you become aware of any security vulnerability, please contact support@ginrummyduels.com immediately.

9.0 Your Rights Under GDPR

If you are located in the European Economic Area (EEA) or United Kingdom, you have the following rights: (1) Right of Access — request a copy of your personal data; (2) Right to Rectification — correct inaccurate data; (3) Right to Erasure ("Right to be Forgotten") — request deletion, subject to legal retention requirements; (4) Right to Restrict Processing; (5) Right to Data Portability; (6) Right to Object to processing based on legitimate interest; (7) Right to Withdraw Consent at any time. To exercise any of these rights, contact support@ginrummyduels.com. Note that certain data (e.g., blockchain transactions) is immutable and cannot be erased.

10.0 Cross-Border Data Transfers & Age Restrictions

Your data is primarily processed within the European Economic Area (EEA). Any transfers outside the EEA are performed in accordance with GDPR Chapter V requirements, including the use of Standard Contractual Clauses (SCCs) where applicable. This Platform is strictly NOT intended for individuals under 18 years of age. We do not knowingly collect personal data from minors. If you believe a minor has provided data to us, please contact support immediately so we can delete it.

11.0 Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or applicable law. Material changes will be communicated via an in-app notification. The revised Policy will indicate the updated effective date. Continued use of the Platform following notification constitutes your acceptance of the update.

For privacy-related inquiries or to exercise your data rights, contact us at support@ginrummyduels.com.