Privacy Policy

THIS PRIVACY POLICY CONTAINS A BINDING ARBITRATION CLAUSE AND A WAIVER OF CLASS ACTIONS IN SECTION 18, WHICH MAY AFFECT YOUR LEGAL RIGHTS. BY USING OUR SERVICES, YOU AGREE TO RESOLVE ANY DISPUTES THROUGH INDIVIDUAL ARBITRATION RATHER THAN IN COURT. PLEASE READ SECTION 18 CAREFULLY. YOU MAY HAVE THE RIGHT TO OPT OUT OF ARBITRATION WITHIN 30 DAYS OF FIRST USE.

1) Introduction. This Privacy Policy explains how Crossbar Holdings Inc., a Delaware corporation ("we," "us," or "our"), collects, uses, and protects your personal information when you use the DopeRaider Telegram-based game ("Service" or “DopeRaider”). This policy applies to all users worldwide and complies with applicable privacy laws including GDPR, CCPA, and other relevant regulations. By using DopeRaider, you agree to this Privacy Policy. We are committed to protecting your privacy while delivering an engaging Web3 gaming experience.

2) Information We Collect. To operate the DopeRaider game and deliver a seamless Web3 experience, we collect several types of personal information. This includes data you provide directly, information generated through your gameplay, and technical details collected automatically.

a) Identity and Account Information. When you interact with the game, we collect information that helps identify you and associate you with your in-game activity. This includes:

· Telegram username and Telegram ID

· In-game username

· Email address (if provided)

· Cryptocurrency wallet addresses

This information is used to create and manage your account, authenticate your identity, and enable blockchain-based features.

b) Gameplay and Technical Information. As you use the Service, we collect data related to your actions and technical environment to improve performance and gameplay. This includes:

· Game progress, in-game purchases, achievements, and player statistics

· Chat messages and interaction history with other users

· Device type, operating system, and browser type

· IP address, time zone, and session timestamps

· Error logs, diagnostic data, and crash reports

We use this information to monitor and enhance game functionality, ensure security, and develop new features tailored to user behavior.

c) Engagement and Marketing Information. We also collect information related to how you engage with our communications and campaigns. This may include:

· Communication preferences and marketing opt-ins

· Responses to promotions, surveys, and in-game events

· Customer support tickets and feedback

· Referral source or platform through which you accessed the game (e.g., Telegram groups, affiliate links)

This helps us understand user interest, improve our communications, and promote relevant Crossbar products and updates.

d) Blockchain Activity. When you engage with Web3 features, we may collect and associate publicly available blockchain data with your profile, including:

· On-chain transaction hashes

· NFT or token balances

· Smart contract interactions related to game functionality

Please note that information recorded on public blockchains is immutable and cannot be altered or deleted by us.

3) How We Use Your Information. We process your personal information for several key purposes, relying on different legal bases depending on your location and the specific use:

a) Service Operations. We use your information to deliver the core game experience and ensure the security and functionality of your account. This includes:

· Creating and maintaining your in-game profile

· Enabling gameplay features and blockchain functionality

· Processing in-game transactions

· Responding to support inquiries

· Securing your account and preventing unauthorized access

This processing is necessary to perform our contract with you and to support our legitimate interest in maintaining a secure and functioning service.

b) Game Improvement and Analytics. To better understand how players engage with DopeRaider, we analyze usage data and technical information to:

· Monitor game performance and detect issues

· Develop new features and refine gameplay

· Understand player preferences and behavior patterns

· Conduct internal research and aggregate reporting

We rely on our legitimate interest in improving the game and ensuring a high-quality user experience.

c) Marketing and Product Promotion. We use your information to promote Crossbar products and keep you informed about updates and offers related to DopeRaider. This includes:

· Sending newsletters, updates, and promotional materials

· Providing personalized content and product recommendations

· Measuring the effectiveness of campaigns and outreach

· Retaining your information for future offers and re-engagement

Processing for these purposes is based on your consent where required, or on our legitimate interest in communicating with our users and building ongoing customer relationships.

d) Legal and Security Compliance. We may also use your data to comply with applicable laws and protect our platform and users. Specifically, we may:

· Investigate and prevent fraud, abuse, or violations of our terms

· Respond to legal requests, such as subpoenas or court orders

· Enforce our rights and defend against legal claims

· Maintain records required by financial, tax, or other regulations

These uses are necessary for compliance with legal obligations and to protect our legitimate interests.

4) How We Share Information

a) Service Providers. We work with trusted third-party providers who help us operate and maintain the DopeRaider platform. These include:

· Cloud hosting services (e.g., AWS, Google Cloud)

· Analytics providers (e.g., Google Analytics, in-game analytics tools)

· Payment processors and cryptocurrency infrastructure providers

· Customer support platforms and communication tools

These providers are contractually bound to process your data only on our behalf and for specified purposes. They are required to implement appropriate security measures and comply with applicable privacy laws.

b) Business Partners. In some cases, we may share limited information with selected partners to enhance your experience or expand our service. For example:

· Blockchain infrastructure partners enabling wallet or token functionality

· Co-marketing partners or affiliated communities (e.g., guilds, Telegram groups)

· Developers of integrated features or in-game experiences

All such sharing is governed by agreements that limit use and require appropriate confidentiality protections.

c) Legal Disclosures. In some cases, we may share limited information with selected partners to enhance your experience or expand our service. For example:

· Blockchain infrastructure partners enabling wallet or token functionality

· Co-marketing partners or affiliated communities (e.g., guilds, Telegram groups)

· Developers of integrated features or in-game experiences

All such sharing is governed by agreements that limit use and require appropriate confidentiality protections.

d) Business Transfers. In the event of a merger, acquisition, restructuring, or sale of assets, your personal information may be transferred as part of that transaction. We will ensure that the recipient upholds this Privacy Policy or provides comparable protections.

e) Blockchain Transparency. Certain information is inherently public due to the nature of blockchain technology. For example, if you engage with Web3 features, your:

· Wallet address

· Transaction history

· NFT or token holdings

may become permanently visible on public blockchain networks. This data is not controlled by Crossbar and cannot be altered or deleted once published.

5) Automated Decisions. We may use automated systems to analyze gameplay behavior, determine in-game rewards, or personalize your experience. These systems help us deliver engaging and relevant content. You have the right to object to such processing under certain conditions (see Section 9).

6) User-Generated Content. Some features may allow users to post messages, content, or gameplay data that can be viewed by others. Please be cautious when sharing personal information. We cannot control how others may use information you disclose in public areas of the Service.

7) Blockchain Transparency Notice. Certain data, such as wallet addresses, NFT ownership, and transaction history, is stored on public blockchains and may be accessible to anyone. This data is immutable and cannot be deleted or altered by us. Please be mindful when interacting with on-chain features.

8) Data Retention. We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including to comply with legal obligations, resolve disputes, and enforce our agreements. The retention period depends on the type of data and the applicable legal or business requirements. Here’s how long we typically keep different types of data:

a) Account Data (such as usernames, wallet addresses, and profiles): retained while your account is active and for up to 7 years after account closure to support audits, legal compliance, and dispute resolution.

b) Transaction Records (including blockchain interactions and in-game purchases): retained for 10 years to meet financial and regulatory obligations.

c) Marketing and Engagement Data (e.g., campaign participation, preferences): retained until you withdraw consent or for up to 2 years after your last interaction with our marketing materials.

d) Technical Logs and Diagnostic Data: retained for up to 2 years, unless required longer for security, fraud prevention, or platform integrity.

e) Blockchain Data: recorded permanently on public decentralized networks and cannot be deleted or altered by us due to the immutable nature of blockchain technology.

Deletion Requests. If you request deletion of your personal information, we will remove data from our active systems within 30 days, unless we are legally required or permitted to retain it. Data stored on blockchain networks is not subject to erasure due to its public and decentralized structure, but we will disconnect or anonymize associated metadata where possible.

9) YOUR PRIVACY RIGHTS. Depending on your location, you have various rights regarding your personal information:

a) Universal Rights (All Users):

· Access your personal information

· Correct inaccurate data

· Request deletion of your information

· Data portability (receive your data in a usable format)

· Object to certain processing

b) Additional GDPR Rights (EU/EEA Users):

· Restrict processing of your information

· Object to automated decision-making

· Withdraw consent at any time

· File complaints with data protection authorities

To exercise these rights, contact us using the information in Section 17. We'll respond within 30 days and may request verification of your identity.

10) International Transfers. Your information may be processed in countries outside your location, including the United States where our primary operations are located. For transfers from the EU/EEA and UK, we use appropriate safeguards such as Standard Contractual Clauses approved by regulators and adequacy decisions for approved countries.

11) Children's Privacy. DopeRaider is not intended for children under 13 (or 16 in the EU). We don't knowingly collect personal information from children below these ages. If we discover we've collected such information, we'll delete it promptly. For teens aged 13-17, we apply enhanced privacy protections and may require parental consent for certain features.

12) Security. We implement comprehensive security measures to protect your information, including:

· Encryption of data in transit and at rest

· Multi-factor authentication and access controls

· Regular security audits and monitoring

· Secure development practices

· Specialized Web3 security measures for blockchain operations

While we use industry-standard security practices, no method of transmission over the internet is completely secure.

13) Cookies And Tracking. We use cookies and similar technologies to operate our service and improve your experience. These include:

a) Essential cookies: Required for basic functionality

b) Analytics cookies: Help us understand usage patterns

c) Marketing cookies: Enable personalized advertising

d) Social cookies: Facilitate social media integration

You can control cookies through your browser settings. We don't currently respond to Do Not Track signals, but you can manage tracking through other privacy controls.

14) California Privacy Disclosures. We don't sell personal information as defined by California law. In the past 12 months, we've collected identifiers (names, emails, IP addresses), commercial information (purchase history), internet activity data, and geolocation information. We may share information for advertising purposes, which California law considers "sharing." We limit use of sensitive personal information to disclosed purposes and don't use it for additional purposes without consent.

15) Policy Updates. We may update this policy periodically to reflect legal changes, new features, or business developments. Material changes will be communicated through prominent notices in the game, email notifications, and other appropriate channels. Changes become effective 30 days after notification unless immediate changes are required by law or are favorable to your privacy.

16) Third-Party Links and Integrations. Our Service may contain links to or integrate with third-party websites, dApps, or social media platforms. We are not responsible for the privacy practices or content of those third parties. We encourage you to review their privacy policies before sharing your information.

17) Contact Us. For questions about this Privacy Policy or to exercise your privacy rights, contact us at:

Crossbar Holdings Inc. Privacy Officer Email: [e-mail]

18) Dispute Resolution. This Privacy Policy and any disputes arising from or relating to your use of the Service shall be governed by the laws of the State of Delaware, without regard to its conflict of law principles. Before initiating any legal action, you agree to first attempt to resolve any dispute with us through good faith negotiation by contacting us at [e-mail]. If we are unable to resolve the matter informally within 30 days, the dispute shall be resolved through binding arbitration as set forth below.

a) Binding Arbitration. Any dispute, claim, or controversy between you and Crossbar (including any affiliates, officers, or employees) arising out of or relating to this Privacy Policy or your use of the Service shall be resolved by final and binding arbitration administered by JAMS pursuant to its Streamlined Arbitration Rules & Procedures, except as otherwise provided herein. The arbitration will take place remotely with a seat in New York, New York, unless otherwise agreed in writing. The proceedings will be conducted in English.

b) No Class Actions. You agree that all claims must be brought on an individual basis, and not as a plaintiff or class member in any purported class or representative proceeding. The arbitrator may not consolidate the claims of multiple individuals or entities.

c) Exceptions. Notwithstanding the foregoing, either party may bring a claim in small claims court if it qualifies or may seek equitable relief in a court of competent jurisdiction to prevent the unauthorized use or misuse of confidential information or intellectual property. Crossbar reserves the right to enforce its rights in any jurisdiction where harm is occurring or likely to occur.

d) Local Remedies. EU/EEA residents may also file complaints with their local data protection authority, and California residents may contact the California Attorney General’s office with concerns. These rights apply only to the extent required by local law and do not waive Crossbar’s rights to require arbitration under U.S. law for all other claims.

e) Arbitration Opt-Out. You may opt out of the arbitration and class action waiver provisions above by sending a written notice of your decision to opt out to [e-mail] with the subject line "Arbitration Opt-Out" within 30 days of your first use of the Service. The opt-out request must include your full name, Telegram username, and a clear statement that you wish to opt out of arbitration. If you do not opt out within this period, you will be bound by the arbitration and class action waiver provisions of this Privacy Policy.