Privacy & Cookie Policy

The Service is operated as an informal, independent software project run by an individual. It is not a licensed or registered financial or gambling operator, and there is no corporate entity, company, or registered data controller behind it — it is an individual, unlicensed project.

Because the Service is non-custodial and account-free, there is very little personal data to be a “controller” of in the first place — see Section 3. For any privacy question or request, contact [email protected].

• No accounts. You interact with the Service by connecting a self-custodied crypto wallet. We never ask you to register, and we never issue you a login.
• No KYC. Because we never take custody of your funds, we do not ask for your name, government ID, proof of address, or other identity documents.
• Data minimisation.We try not to collect information we don’t need to run, secure, and lawfully operate the site.
• No selling of data. We do not sell your personal information, and we do not build advertising profiles about you across other websites.

3.1 Information you provide directly

For most use of the Service, nothing. There is no sign-up form, no profile, and no password. If you choose to email us at [email protected], we will receive whatever you put in that message (for example, your email address and the contents of your request) and keep it only as long as needed to handle your enquiry.

3.2 On-chain and wallet information

When you connect a wallet and use the Service, your public wallet address is used to build, display, and submit blockchain transactions. Your wallet address, your balances, and every transaction you make — including stakes, draws, and payouts in the Games — are recorded on public blockchains (for the Games, BNB Smart Chain / BSC), settled in USDT (BEP-20), and are inherently public and permanent. Anyone can view them on a block explorer such as BscScan. This information is public by the nature of blockchains, not because CoinXchange publishes it; we do not control it and cannot alter or erase it.

3.3 Technical and usage information

To operate and secure the site, we (and the infrastructure providers listed in Section 6) may process standard technical data automatically, including:

• your IP address, as inevitably processed by our hosting and CDN provider to deliver and protect the site — we do not use it to screen your location, geo-block, or gate access (see Section 4);
• device and browser information (such as browser type, operating system, and screen size);
• basic connection and request logs; and
• aggregate, non-identifying usage information about how the site is used.

We use this information only to run, protect, debug, and improve the Service and to meet legal and compliance obligations. We do not use it to build a personal identity profile of you.

3.4 What we do NOT collect

• No names, email addresses (unless you email us), or passwords.
• No KYC identity documents.
• No custody of your funds, private keys, or seed phrases — these never leave your wallet and we never see them.
• No selling of your data and no cross-site advertising profiles.

The Games are decentralized, non-custodial software on a public blockchain. We do not collect, screen, or geo-block based on your location, and we do not verify what country you are in. Eligibility — including that you are not in a Restricted Territory and are of legal age — is by your own representation under the Games Terms and the Eligibility & Restricted Territories notice, not something we technically enforce. The only pre-play control we apply is a self-declared 18+ acknowledgement (a one-time confirmation before the lobby loads); it records your answer and does not verify your age, identity, or location. You are responsible for ensuring the Games are lawful where you live.

We keep browser storage to a minimum and we do not use advertising or cross-site tracking cookies to profile you.

5.1 Strictly necessary / functional

We use a small amount of local storage in your browser to make the site work and to remember your choices — for example, that you have accepted our terms or age/eligibility acknowledgement, your interface preferences, your cookie-consent choice itself, and, where applicable, a temporary session for wallet connection. These are essential to the functioning of a non-custodial dApp and cannot meaningfully be switched off while still using the Service; they are not used for advertising or cross-site tracking.

5.2 Analytics (non-essential)

We may use privacy-conscious, aggregate analytics to understand overall site usage. Any such non-essential analytics are only loaded after you choose “Accept” on our cookie banner — if you decline, or have not yet chosen, no analytics cookies or scripts are set. As of the last-updated date above, no analytics provider is in use, so nothing beyond the strictly-necessary storage in 5.1 is loaded regardless of your choice; the consent mechanism is in place for if that ever changes.

5.3 Advertising / ad-network pixels

The Service may be promoted through crypto-native advertising networks. As of the last-updated date above, no advertising or measurement pixel is present on the site. If one is ever added, it will be disclosed here and gated behind your consent on the cookie banner (treated as non-essential, off by default), with an option to decline.

5.4 Managing cookies

When you first visit, a consent banner lets you Accept or Decline non-essential cookies; non-essential cookies are declined by default until you choose to accept, and your choice is remembered so the banner does not show again. You can also clear or block cookies and local storage through your browser settings; note that clearing essential storage may reset your preferences (including your cookie choice) and require you to re-confirm terms and eligibility.

The Service relies on independent third parties to function. Each operates under its own privacy policy, which we do not control:

• Blockchain networks (including BNB Smart Chain) and RPC / node providers, which broadcast and read on-chain data.
• Chainlink VRF, which supplies the verifiable random number used to settle Games outcomes on-chain.
• Cloudflare, for content delivery, edge routing, and security.
• Wallet providers and connection layers (for example WalletConnect / Reown and your chosen wallet), which handle transaction signing. Your private keys stay with your wallet — we never receive them.
• Third-party protocols that power specific products (for example prediction markets or swap/yield routing), which set their own pricing, liquidity, and data practices.
• Analytics and, if applicable, advertising-measurement vendors, as described in Section 5 (none currently in use).

When you interact with these providers you may be sharing data with them directly. We encourage you to review their policies.

The Games hub (Duels and The Pot) is fully non-custodial and account-free. Every buy-in, random draw, and payout is a smart-contract transaction that moves value wallet-to-wallet on BNB Smart Chain, settled in USDT (BEP-20) and provably fair via Chainlink VRF. As a result:

• We do not hold your funds, and there is no balance or account for us to store, freeze, or return.
• Your game history is your on-chain transaction history, which is public and permanent on the blockchain and outside our control.
• We do not screen your region or location. The only pre-play control is a self-declared 18+/eligibility acknowledgement (18+, or the higher minimum where you are) shown before the lobby loads, as described in Sections 3–4; territory eligibility is by your own representation under the Games Terms. See our Games Terms, Responsible Gaming, Risk Disclaimer, and Eligibility & Restricted Territories notices for the full rules.

We do not sell your data. We may disclose the limited information we hold only where we reasonably believe it is necessary to:

• comply with applicable law, a lawful request, or legal process;
• enforce our terms, prevent fraud, abuse, collusion, or manipulation of the Games; or
• protect the security, integrity, and rights of the Service and its users.

On-chain data is permanent and is not something we can delete — it lives on public blockchains outside our control. Off-chain technical logs and any correspondence you send us are kept only as long as needed for the purposes described in this policy, for security, or to meet legal obligations, and then deleted or anonymised. Because the Service is account-free and collects so little, we hold no personal profiles to retain.

Depending on where you live, you may have rights over personal data we hold about you — such as the right to access, correct, or delete off-chain data, or to object to or restrict certain processing. Please note two practical limits: (1) we hold very little personal data because the Service is non-custodial and account-free, and (2) we cannot alter or erase blockchain records, because we do not control them.

To exercise any right, contact [email protected]. We will do our best to respond to reasonable requests; the specific rights available to you depend on the data-protection law that applies where you live.

The Service is strictly for adults. You must be at least 18 years old, or the higher minimum legal age in your jurisdiction, to use it. We do not knowingly collect information from anyone under that age. If you believe someone underage has used the Service, contact us and we will take appropriate action.

The Service may be accessed from many countries, and the infrastructure providers in Section 6 may process technical data in various locations. Blockchain data is, by nature, globally replicated. By using the Service you understand that limited technical data may be processed outside your home country.

We may update this policy from time to time. When we do, we will revise the “last updated” date above. Continued use of the Service after changes take effect constitutes acceptance of the revised policy. We encourage you to review this page periodically.

Questions, privacy requests, or responsible-gaming concerns can be sent to [email protected]. This inbox is monitored for privacy and compliance matters.