UPSHOT PRIVACY POLICY

1. INTRODUCTION

Upshot ("we," "us," "our," or "Company") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our digital card collecting platform and related services ("Platform" or "Service").

By using our Platform, you consent to the data practices described in this Privacy Policy.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

Account Information:

• Name, username, email address, and password
• Date of birth (for age verification)
• Phone number (for account security)
• Profile photo and bio information

Financial Information:

• Payment method details (credit card, bank account information)
• Cryptocurrency wallet addresses
• Tax identification information (for prize tax reporting)
• Transaction history and payment records

Identity Verification:

• Government-issued ID documents
• Proof of address documents
• Selfie photos for identity confirmation
• Social Security Number or Tax ID (where required for prizes)

Contest and Prize Information:

• Contest entries and submissions
• Prize claim information
• Tax forms and documentation

2.2 Information We Collect Automatically

Device and Usage Information:

• IP address, device type, operating system
• Browser type and version
• Screen resolution and device identifiers
• App usage patterns and session duration
• Pages visited and features used

Blockchain and NFT Data:

• Wallet addresses and transaction hashes
• NFT ownership records and trading history
• Smart contract interactions
• Public blockchain transaction data

Analytics and Performance Data:

• Platform performance metrics
• Error logs and crash reports
• Feature usage statistics
• A/B testing data

2.3 Information from Third Parties

Social Media Integration:

• Profile information from connected social accounts
• Friends lists and social connections
• Public posts and interactions (if you choose to share)

Blockchain Data Providers:

• NFT metadata and ownership verification
• Transaction validation services
• Market price and trading data

Payment Processors:

• Transaction verification and fraud prevention
• Payment method validation
• Chargeback and dispute information

3.5 Analytics & Measurement

We use Amplitude, Inc. and similar analytics providers to help us understand how the Platform is used, diagnose performance issues, and improve new features. These tools collect event information such as the pages or menu items you open (e.g., navigation events), card or pack interactions, timestamps, approximate location (derived from IP address), device/browser data, and identifiers that Amplitude generates. Analytics data may be combined with your account ID or wallet address when necessary to troubleshoot issues or assess product adoption.

We rely on your consent where required (for example, via cookie or analytics preference banners in the EU/UK) or otherwise process this data under our legitimate interests in maintaining and improving the Platform. You can opt out of analytics at any time through the Platform's cookie/settings controls, by enabling a supported Global Privacy Control (GPC) signal in your browser, or by contacting us at the address in Section 9. If you opt out, we will record your preference and stop sending new analytics events from that device, but we may retain aggregated and de-identified reports generated before your opt out.

3. HOW WE USE YOUR INFORMATION

3.1 Primary Platform Functions

• Create and manage your account
• Process NFT transactions and trades
• Facilitate contest participation and prize distribution
• Verify identity and prevent fraud
• Process payments and withdrawals

3.2 Communication and Support

• Send account notifications and updates
• Provide customer support services
• Share contest results and announcements
• Send marketing communications (with consent)

3.3 Legal and Compliance

• Comply with tax reporting requirements
• Meet anti-money laundering (AML) obligations
• Respond to legal requests and investigations
• Enforce our Terms and Conditions

3.4 Platform Improvement

• Analyze usage patterns and user behavior
• Develop new features and services
• Conduct research and analytics
• Perform security monitoring and threat detection

4. HOW WE SHARE YOUR INFORMATION

4.1 Service Providers

We share information with trusted third-party service providers who assist us in:

• Payment processing and financial services
• Identity verification and fraud prevention
• Cloud hosting and data storage
• Customer support and communication tools
• Analytics and marketing services

4.2 Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal processes and government requests
• Enforce our Terms and Conditions
• Protect our rights, property, and safety
• Investigate fraud or security incidents

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal information may be transferred to the new entity.

4.4 Contest and Prize Administration

• Tax authorities (for prize tax reporting)
• Prize fulfillment partners
• Contest verification services
• Public winner announcements (with consent)

4.5 Blockchain Transparency

Certain information is publicly available on the blockchain, including:

• Wallet addresses and transaction history
• NFT ownership and trading records
• Smart contract interactions

5. DATA SECURITY

5.1 Security Measures

We implement industry-standard security measures including:

• Encryption of data in transit and at rest
• Multi-factor authentication options
• Regular security audits and penetration testing
• Secure development practices
• Employee access controls and training

5.2 Blockchain Security

• Private key management best practices
• Smart contract security audits
• Secure wallet integration protocols
• Transaction monitoring and anomaly detection

5.3 Data Breach Response

In the event of a data breach, we will:

• Notify affected users promptly
• Report to relevant authorities as required
• Take immediate steps to contain the breach
• Provide guidance on protective measures

6. YOUR PRIVACY RIGHTS

6.1 Access and Control

You have the right to:

• Access your personal information
• Update or correct inaccurate data
• Delete your account and associated data
• Download your data in a portable format
• Opt out of marketing communications

6.2 Regional Privacy Rights

For EU Residents (GDPR):

• Right to be forgotten
• Right to data portability
• Right to restrict processing
• Right to object to processing
• Right to withdraw consent

For California Residents (CCPA):

• Right to know what personal information is collected
• Right to delete personal information
• Right to opt-out of sale of personal information
• Right to non-discrimination

For Other Jurisdictions:

We comply with applicable local privacy laws and regulations.

7. DATA RETENTION

7.1 Retention Periods

• Account information: Retained while account is active plus 7 years
• Financial records: 7 years for tax and legal compliance
• Contest data: 7 years for prize verification and tax reporting
• Marketing data: Until you opt out or 3 years of inactivity
• Blockchain data: Permanently recorded on public blockchain

7.2 Deletion Requests

When you request account deletion, we will:

• Remove personal information from active systems
• Retain certain data as required by law
• Note that blockchain records cannot be deleted

8. INTERNATIONAL DATA TRANSFERS

8.1 Cross-Border Processing

Your information may be processed in countries other than your residence, including:

• United States (primary data processing)
• European Union (EU users)
• Other countries where our service providers operate

8.2 Transfer Safeguards

We ensure appropriate safeguards for international transfers through:

• Standard Contractual Clauses
• Adequacy decisions
• Privacy Shield frameworks (where applicable)
• Other legally recognized transfer mechanisms

9. CHILDREN'S PRIVACY

9.1 Age Restrictions

• Our Platform is not intended for users under 18
• We do not knowingly collect information from minors
• Parents should monitor their children's internet usage

9.2 Parental Rights

If you believe we have collected information from a minor:

• Contact us immediately at [privacy@upshot.com]
• We will investigate and delete the information
• We will block future access from that account

10. COOKIES AND TRACKING

10.1 Types of Cookies

We use the following types of cookies:

• Essential cookies: Required for platform functionality
• Analytics cookies: Help us understand usage patterns
• Marketing cookies: Deliver personalized advertisements
• Social media cookies: Enable social sharing features

10.2 Cookie Management

You can control cookies through:

• Browser settings and preferences
• Our cookie consent manager
• Third-party opt-out tools
• Mobile device advertising settings

11. THIRD-PARTY LINKS AND SERVICES

11.1 External Links

Our Platform may contain links to third-party websites and services. We are not responsible for their privacy practices.

11.2 Integrated Services

We integrate with third-party services including:

• Cryptocurrency wallets and exchanges
• Social media platforms
• Payment processors
• Analytics providers

Each service has its own privacy policy that governs your interactions.

12. UPDATES TO THIS POLICY

12.1 Policy Changes

We may update this Privacy Policy to reflect:

• Changes in our data practices
• New legal requirements
• Platform feature updates
• User feedback and requests

12.2 Notification of Changes

We will notify you of material changes through:

• Email notifications
• Platform announcements
• Updated effective date
• Prominent notices on our website

13. CONTACT INFORMATION

13.1 Privacy Questions

For questions about this Privacy Policy or our data practices:

• Email: [privacy@upshot.com]
• Address: [Company Address]
• Phone: [Phone Number]

13.2 Data Protection Officer

For EU residents, you may contact our Data Protection Officer at:

• Email: [dpo@upshot.com]

13.3 Regulatory Complaints

You have the right to file complaints with relevant data protection authorities in your jurisdiction.