PRIVACY POLICY

This Privacy Policy describes how METAWELL SPORTS LIMITED ("we", "us", "our", or "the Company") collects, uses, discloses, stores, protects, and otherwise processes your personal information when you use the CPL Esports mobile application ("App" or "Services"), including features related to skill-based cricket esports gameplay, NFT collectibles, and play-to-earn rewards. This Policy applies to our App available on Google Play Store and Apple App Store.

Important Notes:
The App does not integrate any payment gateways or handle financial transactions directly.
By downloading, installing, or using the App, you agree to this Privacy Policy. If you do not agree, please do not use the Services.

We are committed to protecting your privacy in compliance with applicable laws, including the UAE Federal Decree-Law No. 45/2021 on the Protection of Personal Data ("PDPL"), the EU General Data Protection Regulation ("GDPR") where applicable, the California Consumer Privacy Act ("CCPA") as amended by the California Privacy Rights Act ("CPRA"), the Children's Online Privacy Protection Act ("COPPA"), the Indian Digital Personal Data Protection Act, 2023 ("DPDP Act") where applicable, and other relevant regulations.

This Policy meets the requirements for app listings on Google Play Store and Apple App Store, with full transparency on data handling for Web3 features.

1. Data Controller and Contact Information

Data Controller: METAWELL SPORTS LIMITED

A company licensed by the Government of Ras Al Khaimah under the Ras Al Khaimah Digital Assets Oasis (RAK DAO) free zone for digital assets, Web3, esports, gaming, AI, metaverse, and healthtech.

Head Office and Registered Address:
Office i, RAK Business Centre, Innovation City Building, RAK Bank Operations Centre, Ground Floor, Al Rifaa, Sheikh Mohammed Bin Zayed Road, Ras Al Khaimah, United Arab Emirates

Contact Email: support@cplgames.io
Data Protection Officer: md@metawellsports.com

We act as the Data Controller for personal data processed through the App. For inquiries, complaints, or rights exercises, contact us at the above email.

2. Types of Data Collected

We collect only the minimum data necessary to provide a secure, skill-based esports experience. Personal Data refers to information that identifies or relates to an identifiable individual. We do not collect sensitive personal data (e.g., racial/ethnic origin, health, biometrics, or political opinions) unless required by law. The App does not process any payment-related data.

2.1 Data You Provide

Account and Registration Data: Email address, username (required for account creation, personalization, and leaderboards).
Contact Data: Optional name or additional details if you contact support.

2.2 Data Collected Automatically

Device and Technical Data: Device ID, IP address, operating system, app version, and browser type (for anti-cheat measures, security, and compatibility).
Gameplay and Usage Data: Match history, performance statistics, in-game actions, and anonymized analytics (to improve gameplay, detect bugs, and ensure fair play).
Web3 and Blockchain Data: Optional public blockchain wallet addresses (for NFT ownership and skill-based rewards; no private keys or seed phrases are collected or stored).

2.3 Other Data

Location Data: Approximate location (inferred from IP or device settings, if enabled) for regional matchmaking or tournaments (with consent).
Aggregated/Anonymized Data: Non-personal data derived from usage (e.g., general trends) used for internal research and improvements.

We do not use Advertising ID, track for targeted advertising, or collect data from children under 13.

3. How We Use Your Data (Purposes and Legal Bases)

We process data for the following purposes, based on the legal bases outlined below:

To Provide and Operate the Services (Contract Performance): Account management, gameplay facilitation, skill-based NFT rewards (e.g., collectible player cards earned through performance for in-game enhancements), and tournament participation.
To Enhance Security and Prevent Fraud (Legitimate Interests): Anti-cheat detection, account protection, and fraud monitoring.
To Improve the App (Legitimate Interests): Analytics on usage patterns to optimize features and fix issues.
To Provide Support (Contract Performance/Consent): Responding to inquiries and resolving disputes.
For Legal Compliance (Legal Obligation): Age verification, AML/KYC checks (if required), and responding to authorities.
For Marketing (Consent): Optional emails about updates or promotions (withdraw consent anytime).
Web3 Features: Processing public wallet addresses for blockchain interactions (e.g., NFT minting/ownership; NFTs are enhancements only, not investments or speculative tools).

Under GDPR, legitimate interests are balanced against your rights (e.g., via impact assessments). For CCPA/CPRA, we do not "sell" or "share" personal information as defined. For DPDP Act, processing is purpose-limited with consent where required.

4. Sharing and Disclosure of Data

We do not sell, rent, or trade personal data. Disclosure is limited to:

Service Providers (Processors): Third-party vendors for hosting (e.g., AWS/Google Cloud), analytics (e.g., Firebase), and blockchain networks (e.g., OPBNB for NFTs) — all under strict data protection agreements.
Legal and Regulatory Requirements: To comply with laws, court orders, or authorities (e.g., UAE regulators, EU data protection bodies).
Business Transfers: In mergers/acquisitions (with notice).
With Your Consent: For optional features.

Third-party links (e.g., to separate NFT marketplace or wallet providers) are governed by their policies.

5. Blockchain and NFT Specifics

NFTs in CPL Esports are skill-based digital collectibles (e.g., player cards/gear) earned through gameplay to enhance user experience, not for financial speculation or real-money wagering. The NFT marketplace is a separate web-based service; the App does not handle transactions. Blockchain transactions are immutable and publicly verifiable but pseudonymous. We do not control blockchain data; deletion requests may be limited (we anonymize app-side links). Wallet security is your responsibility — we never request private keys.

6. Data Storage, Security, and Retention

Storage Location: Primarily in UAE-based servers (PDPL-compliant); some processing via global clouds with data residency options.

Security Measures: AES-256 encryption at rest/transit, SSL/TLS, firewalls, access controls, regular audits, and vulnerability scans.

Retention Periods:

Account Data: While active + 2 years post-deletion (for legal/disputes).
Usage/Gameplay Data: Up to 12 months, then anonymized.
Wallet Data: Until disconnection/request.

Data is deleted securely when no longer needed.

7. International Data Transfers

Transfers outside UAE (e.g., to EU/US for cloud services) use safeguards like Standard Contractual Clauses (GDPR), adequacy decisions, or equivalent PDPL mechanisms to ensure protection.

8. Your Rights

You have rights under applicable laws:

Access: View your data.
Rectification: Correct inaccuracies.
Erasure: Delete data (subject to retention; blockchain limitations apply) - Refer to Point 14 for more details.
Restriction/Objection: Limit or oppose processing.
Portability: Receive data in a structured format.
Withdraw Consent: Anytime for consensual processing.
Opt-Out (CCPA/CPRA): Of any sale/sharing (none occur); no discrimination.
Complaints: To UAE Data Office, EU supervisory authorities, or CA Attorney General.

Exercise rights via support@cplgames.io (free, response within 1 month; ID verification required).

9. Children's and Age Privacy

The App is strictly for users aged 18 and above. Users under 18 are not allowed to play, register, or use the App. The App is not directed to children under 13 (COPPA) or under 16 (GDPR Article 8). We do not knowingly collect data from minors. If we discover data from an under-18 user, we delete it immediately.

10. Cookies and Tracking Technologies

We use essential/performance cookies for functionality (e.g., session management) and analytics. No tracking for ads or Advertising ID. Manage via device settings; disabling may limit features.

11. Tax Responsibilities

Any taxes from rewards/NFTs (handled via separate web marketplace) are your responsibility; we do not withhold or report on your behalf. Consult a tax advisor.

12. Changes to This Privacy Policy

We may update this Policy. Changes will be posted here with the updated date; significant changes notified in-app or via email. Continued use constitutes acceptance.

13. Questions and Complaints

Contact support@cplgames.io for any concerns. For unresolved issues, contact relevant authorities.

We value your trust and are committed to compliant, transparent data practices. Thank you for using CPL Esports!

14. Delete Your Account on the Mobile App

At "METAWELL SPORTS LIMITED" we respect your privacy and provide users the ability to delete their account and associated data.

How to Request Account Deletion

To delete your account, please:

Open the app
Go to Settings
Tap Delete Account
Confirm your request

Send an email to: support@cplgames.io
Subject line: Account Deletion Request
Include the email address associated with your account.

What Data Will Be Deleted

When your account is deleted, we permanently delete:

Profile information (name, email, photo)
Account credentials
User-generated content
App usage data linked to your account

Data That May Be Retained

We may retain certain data for:

Legal compliance
Fraud prevention
Financial record-keeping (if applicable)

Retention period: Up to 30 days after deletion request, unless required longer by law.

Processing Time

Deletion requests are processed within 7 business days.

If you have questions, contact: support@cplgames.io

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