Privacy Policy

This Privacy Policy (the "Policy") describes how DrawRace and its affiliates (collectively, "DrawRace", the "Company", "we", "us" or "our") collect, use, process, disclose, retain, and safeguard information in connection with your access to and use of the website at drawrace.xyz, the application at play.drawrace.xyz, and all related services (collectively, the "Platform"). This Policy applies to all Users of the Platform and forms part of, and is incorporated by reference into, our Terms of Service. By using the Platform, you consent to the practices described in this Policy.

We may collect information that you provide directly to us, including an email address and any other registration details you supply; information generated through your use of the Platform, including account identifiers, generated wallet public keys, deposit and withdrawal addresses, contest history, gameplay inputs, wager amounts, and settlement records; and information collected automatically, including device and browser characteristics, internet protocol (IP) address, approximate geolocation derived therefrom, operating system, referring and exit pages, timestamps, and interaction telemetry.

We do not knowingly collect or store the private keys associated with your custodial Wallet in plaintext form, and any encryption keys are maintained in accordance with our internal security controls.

We use the information we collect to operate, maintain, secure, and improve the Platform; to create and administer your account and custodial Wallet; to process deposits, wagers, settlements, and withdrawals; to detect, investigate, and prevent fraud, collusion, cheating, money laundering, and other prohibited or unlawful activity; to comply with legal, regulatory, and law-enforcement obligations; to communicate with you regarding service announcements, security alerts, and support requests; and to analyze usage trends in order to enhance functionality and user experience.

Where applicable law requires a legal basis for processing, we rely upon one or more of the following: the performance of a contract to which you are a party; compliance with a legal obligation to which we are subject; the legitimate interests pursued by us or a third party, provided such interests are not overridden by your fundamental rights and freedoms; and, where required, your consent, which you may withdraw at any time without affecting the lawfulness of processing conducted prior to such withdrawal.

We and our service providers may use cookies, local storage, pixels, and similar tracking technologies to operate and secure the Platform, remember your preferences, maintain session continuity, and measure and analyze traffic and performance. You may configure your browser to refuse or delete cookies; however, doing so may impair certain features or render portions of the Platform inoperable.

You acknowledge and understand that transactions conducted on the Solana blockchain, including deposits, wagers, settlements, withdrawals, token transfers, and burns, are recorded on a public, immutable, and permanent distributed ledger that is outside the control of the Company. Such on-chain data is, by its nature, public, pseudonymous, and irreversible, may be observed, correlated, and analyzed by any third party, and cannot be altered, deleted, or rendered private by the Company upon request or otherwise.

We may disclose information to service providers, vendors, and contractors who perform services on our behalf and who are bound by contractual confidentiality obligations; to regulators, courts, law-enforcement agencies, or other governmental authorities where we believe in good faith that disclosure is necessary to comply with applicable law, legal process, or a lawful governmental request; to protect the rights, property, safety, or security of the Company, our Users, or the public; and in connection with, or during negotiations of, any merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets.

We retain personal information for as long as necessary to fulfil the purposes described in this Policy, to provide the Platform, to comply with our legal, accounting, tax, and regulatory obligations, to resolve disputes, and to enforce our agreements, after which we will delete, anonymize, or aggregate such information in accordance with applicable law and our internal retention schedules.

We implement and maintain reasonable administrative, technical, and organizational measures designed to protect information against unauthorized access, loss, misuse, alteration, or destruction. Nevertheless, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot and do not guarantee the absolute security of any information you transmit to or store on the Platform.

Your information may be collected, transferred to, stored, and processed in jurisdictions other than your own, the data protection laws of which may differ from those of your jurisdiction of residence. Where required, we will implement appropriate safeguards in respect of such transfers. By using the Platform, you consent to the transfer of your information to such jurisdictions.

Depending upon your jurisdiction, you may have the right to access, correct, update, port, restrict, or request deletion of certain personal information, to object to certain processing, and to lodge a complaint with a supervisory authority. You acknowledge that certain information recorded on a public blockchain is technologically incapable of correction or deletion, and that we may be required to retain certain information to comply with our legal obligations or to establish, exercise, or defend legal claims.

The Platform is not directed to, and is not intended for use by, any individual under the age of eighteen (18) or the age of legal majority in their jurisdiction. We do not knowingly collect personal information from such individuals, and if we become aware that we have inadvertently done so, we will take reasonable steps to delete such information.

We may amend or update this Policy from time to time in our sole discretion. Any changes will be effective upon posting of the revised Policy to the Platform, with the "Last updated" date reflecting the date of the most recent revision. Your continued use of the Platform following the posting of any revised Policy constitutes your acceptance of such changes.