CHIPS PRIVACY POLICY

Version 1.0 — Last updated September 2, 2026 — Effective September 2, 2026

SUMMARY

This Privacy Policy explains what information Stonksino collects when you use stonksino.xyz and our related services, why we collect it, who we share it with, how long we keep it, and the choices and rights you have. The short version:

We do not ask for your name or identity documents to open an Account. Your Account is identified by your wallet address, and optionally by a username and email address.
We collect technical and behavioral information — including your IP address, device fingerprint, gameplay data and on-chain transaction data — to run the Platform, to operate the Fairness Guarantee, to keep the Platform secure, and to detect exploits, multi-accounting and ban evasion.
Transactions on Solana are public and permanent. We cannot delete or hide them.
We do not sell your personal information.
We keep records of bans, self-exclusions and the identifiers linked to them for as long as needed to enforce them, even if you ask us to delete your Account.
You can access, export, correct and (subject to limits) delete your information, and you can object to certain uses. Section 12 explains how.

1. WHO WE ARE AND HOW TO CONTACT US

The Platform is operated by [OPERATOR ENTITY], [REGISTERED ADDRESS] (the "Operator", "Stonksino", "we", "us" or "our"). The Operator is the controller of the personal information described in this Policy. You can contact us about privacy at privacy@stonksino.xyz. Capitalized terms not defined in this Policy have the meanings given in the Stonksino Terms of Service (the "Terms").

2. WHAT THIS POLICY COVERS

This Policy applies to personal information we collect through stonksino.xyz and its subdomains, our web and mobile experiences, our APIs and bots, our in-Platform chat, our support channels, our community and social media accounts, and any other service that links to this Policy (together, the "Platform"). It does not apply to third-party websites, wallets, block explorers, protocols or services that you access through the Platform, which have their own privacy practices.

3. INFORMATION WE COLLECT

3.1 Information you give us

Wallet information. The public address of each wallet you connect, the authentication messages you sign, and the addresses you save to your Withdrawal Address Book. We never receive your private keys or seed phrase.
Account details. Your username, your email address if you add one, your two-factor authentication configuration (we store the secret needed to verify codes, not your authenticator app data) and hashed recovery codes, your language, display and notification settings, and your hotkey, turbo mode, auto-bet and fairness (client seed) settings.
Responsible gambling settings. Any daily loss limit, cool-off period, deposit or wager limit or self-exclusion you set, together with the dates and duration.
Communications. Messages you send us through support, email, social media or community channels, appeals, discrepancy claims, vulnerability reports, and any attachments you include.
Chat and community content. Messages, usernames and other content you post in Platform chat or community features.
Promotions, surveys and referrals. Information you provide when you enter a promotion, leaderboard or giveaway, respond to a survey, or participate in a referral or affiliate program, including social media handles.
Verification information (only if we ask for it). Where we require verification under the Terms — for example in response to suspicious activity, a legal request or a large withdrawal — we may collect your name, date of birth, address, photographs or scans of identity documents, a selfie or liveness check, proof of address, proof of source of funds or wealth, and proof of wallet ownership. We do not collect this information unless we ask for it.

3.2 Information we collect automatically

Device and browser information. Device type, operating system, browser type and version, screen resolution and color depth, installed fonts, language and time zone settings, hardware concurrency, touch support, canvas, WebGL and audio rendering characteristics, browser extensions that are detectable, and similar signals. We combine these into a device fingerprint that helps us recognize a device across sessions and Accounts.
Network information. Your IP address, approximate location derived from your IP address, internet service provider, autonomous system number, whether the connection appears to come from a VPN, proxy, Tor exit node, data center or hosting provider, and connection characteristics.
Session information. Login and logout times, session identifiers, authentication events, 2FA events, device session records shown in your Device Session Management area, and security events such as failed logins or address book changes.
Gameplay information. Every Bet you place, including the Game, mode (Real or Paper), stake, settings, timestamps, server seed hash, client seed, nonce, revealed server seed, outcome and payout; your auto-bet configurations and stop rules; your rakeback, XP, level and leaderboard data; and per-Bet detail and verification records.
Transaction information. Deposits, withdrawals, trades (including take-profit and stop-loss instructions), conversions, fees, Balance changes, transaction hashes, block numbers, addresses involved, and the internal ledger entries that record them.
Behavioral information. How you interact with the Platform, including pages viewed, features used, timing and sequence of actions, betting patterns, click and input timing, and similar signals that we analyze to keep the Platform secure and fair.
Usage and diagnostic information. Log files, error reports, crash reports, performance data, referring URLs and the pages you visit before and after the Platform.
Cookies and similar technologies. See Section 8.

3.3 Information we collect from other sources

Public blockchain data. Solana is a public ledger. We collect and analyze information from it, including the transaction history, balances, counterparties, token holdings and clustering of any wallet you connect or transact with, and we may do so using third-party blockchain analytics providers.
Screening and risk providers. Results of sanctions, politically exposed person, adverse media, wallet risk and fraud screening from third-party providers.
Geolocation and fraud prevention providers. IP intelligence, VPN and proxy detection results, device intelligence and fraud scores.
Verification providers. Results of identity, age, address and liveness checks where we have asked you to verify.
Affiliates, referrers and partners. Information about how you were referred to the Platform, and information from streamers, creators or partners who promote the Platform.
Social media and community platforms. Public profile information and interactions when you engage with us on X, Discord, Telegram or other platforms.

3.4 Information about other people

If you give us information about another person — for example in a support message, a report, or a referral — you must have the right to do so, and you confirm that you have told them about this Policy.

4. HOW WE USE INFORMATION AND OUR LEGAL BASES

We use personal information for the purposes below. Where the General Data Protection Regulation or the UK GDPR applies, we also identify the legal basis on which we rely.

Providing the Platform
What we do
Create and manage your Account, authenticate you, credit deposits, settle Bets, execute trades, calculate rakeback and XP, run leaderboards, process withdrawals, and provide support
Legal basis
Performance of our contract with you (the Terms)
Operating the Fairness Guarantee
What we do
Generate and commit server seeds, record client seeds and nonces, produce and store per-Bet outcomes, reveal seeds on rotation, and operate the verifier
Legal basis
Performance of our contract; our legitimate interest in demonstrating that Games are fair
Security and integrity
What we do
Protect Accounts, wallets and the Platform from unauthorized access, attacks, fraud and abuse; manage sessions and 2FA; monitor for anomalies; investigate incidents
Legal basis
Our legitimate interests in securing the Platform and protecting users; legal obligations
Enforcing the Terms
What we do
Detect, investigate and act on Exploits, unauthorized automation, multi-accounting, collusion, Benefit abuse, market manipulation and Ban Evasion, including by device fingerprinting, IP and network analysis, behavioral analytics, wallet clustering and cross-Account linking; maintain records of banned persons and linked identifiers; recover value obtained through Exploits
Legal basis
Our legitimate interests in operating a fair Platform, preventing loss and enforcing our rights; legal obligations
Eligibility and location controls
What we do
Determine your approximate location, detect VPNs and proxies, block Restricted Jurisdictions, and enforce age and eligibility rules
Legal basis
Legal obligations; our legitimate interests in complying with the laws that apply to us
Responsible gambling
What we do
Apply loss limits, cool-offs, deposit and wager limits and self-exclusions; recognize and block self-excluded persons, including across Accounts; monitor for signs of harm and contact you where appropriate
Legal basis
Performance of our contract; legal obligations; our legitimate interest and yours in preventing gambling harm; where required, your consent
Anti-money-laundering, sanctions and legal compliance
What we do
Screen wallets and transactions, request and review verification information, assess source of funds, keep records, respond to lawful requests from authorities, and file reports where required
Legal basis
Legal obligations; our legitimate interests in preventing crime and protecting the Platform
Communicating with you
What we do
Send service messages, security alerts, notices about changes to the Terms or this Policy, responses to your requests, and, with your consent where required, marketing about Stonksino promotions and features
Legal basis
Performance of our contract; legal obligations; our legitimate interests; consent for marketing where required
Analytics and improvement
What we do
Understand how the Platform is used, fix errors, test features, measure performance and develop new Games and features
Legal basis
Our legitimate interests in improving the Platform; consent for non-essential analytics cookies where required
Promotions and community
What we do
Run leaderboards, promotions, giveaways, referral and affiliate programs, and display usernames and gameplay statistics in public features
Legal basis
Performance of our contract; our legitimate interests in promoting the Platform
Establishing, exercising and defending legal claims
What we do
Investigate and respond to disputes, appeals, discrepancy claims and complaints; pursue recovery of assets; defend claims
Legal basis
Our legitimate interests; legal obligations
Business transfers
What we do
Evaluate or carry out a merger, acquisition, financing, reorganization or sale of the Platform
Legal basis
Our legitimate interests

Where we rely on legitimate interests we have assessed that those interests are not overridden by your rights and interests. You can ask for more information about that assessment at privacy@stonksino.xyz.

5. AUTOMATED DECISION-MAKING

We use automated systems to score risk and to detect fraud, Exploits, automation, multi-accounting, location circumvention and Ban Evasion. These systems may automatically restrict a feature, hold a withdrawal, freeze or suspend an Account, or block access from a location. Because gambling platforms are targets for abuse, these measures are necessary for entering into and performing the Terms and for protecting the Platform and other users. Where an automated decision has a significant effect on you, you may ask for human review by appealing under the Terms or by contacting privacy@stonksino.xyz, you may express your point of view, and you may contest the decision. Human review considers the same records but is carried out by a person who was not involved in the original decision.

We share personal information only as described below. We do not sell personal information.

Service providers. Companies that provide services to us under contract and on our instructions, such as hosting and infrastructure providers, RPC and node providers, database and backup providers, email and notification providers, customer support tools, device intelligence and fraud prevention providers, IP geolocation and VPN detection providers, blockchain analytics and wallet screening providers, identity verification providers (where we ask you to verify), analytics providers, security and monitoring providers, and professional advisers. [List key providers here, for example: hosting — [•]; RPC — [•]; device intelligence — [•]; blockchain analytics — [•]; verification — [•].]
The Stonksino team. Team members, contractors and moderators who need access to perform their roles, under confidentiality obligations and access controls.
Other users and the public. Your username, level, badges and gameplay statistics may be visible to other users in leaderboards, activity feeds, chat and promotions. Anything you post in chat or community features is visible to other users. Your wallet address and all of your on-chain transactions, including deposits to and withdrawals from the Platform, are visible to anyone on Solana.
Counterparties for recovery and enforcement. Where we investigate an Exploit, Ban Evasion, fraud, theft or other prohibited conduct, we may share Account, wallet, device and transaction information with other platforms, exchanges, wallet providers, blockchain analytics providers, industry fraud-prevention networks, law enforcement and our legal advisers, for the purposes of investigation, prevention and recovery.
Authorities and legal process. Regulators, law enforcement, courts, tax authorities and other public bodies where we are required to do so by law, where we reasonably believe disclosure is necessary to comply with legal process, to protect the rights, property or safety of any person, or to detect, prevent or address fraud, security or technical issues.
Business transfers. A prospective or actual acquirer, investor, successor or any entity formed to operate the Platform, and their advisers, in connection with a merger, acquisition, financing, reorganization, bankruptcy or sale of all or part of our business or assets.
With your direction or consent. Any other party where you have asked us to share or have consented.
Aggregated and de-identified information. We may share statistics and other information that cannot reasonably be used to identify you.

7. PUBLIC BLOCKCHAIN INFORMATION

Solana is a public, permissionless, permanent ledger. When you deposit to or withdraw from the Platform, or trade tokens, the transaction — including your wallet address, our deposit address, the token, the amount and the time — is written to the blockchain and can be viewed, copied, analyzed and linked by anyone, indefinitely. We do not control the blockchain and cannot modify, delete or restrict access to information recorded on it. If you want to limit the linkability of your on-chain activity, use a wallet that you do not use for other purposes. Please also note that anyone who knows your wallet address can look up your Stonksino deposit and withdrawal history on a block explorer.

8. COOKIES, LOCAL STORAGE AND SIMILAR TECHNOLOGIES

8.1 What we use. We use cookies, local storage, session storage, IndexedDB, pixels, software development kits and similar technologies ("cookies") on the Platform for the following purposes:

Strictly necessary. Keeping you signed in, maintaining your session, remembering your wallet connection, protecting against cross-site request forgery, enforcing 2FA, load balancing and other functions without which the Platform cannot operate. These cannot be switched off.
Preferences. Remembering your language, display settings, hotkeys, turbo mode, auto-bet settings, client seed, selected Game mode and other choices.
Security and fraud prevention. Generating and storing device and browser fingerprints, detecting automation and bots, recognizing returning devices, and linking devices to Accounts for the purposes described in Section 4. We consider these necessary to operate a safe Platform.
Analytics. Understanding how the Platform is used and how it performs, using first-party and third-party analytics tools.
Advertising and measurement (if used). [Measuring the effectiveness of our promotions on X or other platforms and recognizing whether you arrived from one of our campaigns. Where these cookies are used we will request your consent where the law requires it.]

8.2 Your choices. You can control cookies through your browser settings, including by deleting cookies and blocking new ones, and through any cookie preference tool we provide on the Platform. Blocking strictly necessary or security cookies may prevent you from using the Platform, and clearing local storage will reset your preferences. The Platform does not currently respond to browser "Do Not Track" signals. Where the law requires it, we honor recognized opt-out preference signals such as Global Privacy Control for the purposes to which they apply.

9. HOW LONG WE KEEP INFORMATION

We keep personal information for as long as needed for the purposes described in this Policy, and afterwards for as long as required by law, needed to resolve disputes, or needed to enforce our agreements. Our ordinary retention periods are:

Account details, wallet addresses and settings: For the life of your Account and [5] years after closure
Gameplay records, provably fair data, Balance ledger and transaction records: [5] years after the Bet or transaction, or longer where required by tax, anti-money-laundering or gaming laws
Verification information, where collected: [5] years after the closure of your Account, or longer where required by law
Security, session, device and network logs: [12–24] months, or longer where relevant to an investigation
Records relating to bans, suspensions, Exploits, Ban Evasion and linked identifiers: For as long as needed to enforce the ban and prevent evasion, which may be indefinitely
Self-exclusion records and linked identifiers: For the duration of the exclusion and [7] years afterwards, or indefinitely for permanent exclusions, so that we can honor the exclusion
Support, appeal and dispute communications: [3] years after the matter is closed, or longer where relevant to a legal claim
Chat and community content: [12] months, unless retained for moderation, investigation or legal purposes
Marketing preferences and consent records: For as long as your consent or objection remains relevant, so that we can honor it
Analytics data: [26] months, or in aggregated form indefinitely

When information is no longer needed we delete it or de-identify it. Information written to the blockchain cannot be deleted by us.

10. HOW WE PROTECT INFORMATION

We use technical and organizational measures designed to protect personal information, including encryption in transit and at rest, hashed storage of secrets and recovery codes, two-factor authentication, device session management, role-based access controls, logging and monitoring, segregated hot and cold wallets for Platform assets, and security testing. No system is completely secure, and we cannot guarantee that unauthorized access, disclosure, alteration or destruction will never occur. You are responsible for keeping your wallet keys, seed phrase, 2FA device and recovery codes safe and for using the security features we provide. If we become aware of a breach affecting your personal information we will notify you and any relevant authority where the law requires it. Please report security concerns to security@stonksino.xyz.

11. INTERNATIONAL TRANSFERS

We operate globally and our servers and service providers are located in [HOSTING REGION] and other countries, which may have data protection laws that differ from those in your country. Where we transfer personal information from the European Economic Area, the United Kingdom or Switzerland to a country that has not been recognized as providing adequate protection, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum, together with supplementary measures where needed. You can request a copy of the relevant safeguards at privacy@stonksino.xyz.

12. YOUR RIGHTS AND CHOICES

12.1 Rights available to everyone. Regardless of where you live, you can:

Access and export. View most of your Account, gameplay and transaction data in your Account, and download a copy using the data export feature or by contacting us.
Correct. Update your username, email address, settings and Withdrawal Address Book in your Account, and ask us to correct other inaccurate information.
Delete. Ask us to close your Account and delete your personal information, subject to the limits in Section 12.4.
Manage marketing. Opt out of marketing emails using the unsubscribe link in any message or through your Account settings. We will still send service and security messages.
Manage cookies. As described in Section 8.2.
Responsible gambling controls. Set limits, cool-offs and self-exclusions in your Account at any time.

12.2 Additional rights in the EEA, the United Kingdom, Switzerland and similar jurisdictions. If you are in a jurisdiction whose law provides them, you also have the right to: restrict our processing in certain circumstances; object to processing based on our legitimate interests, including profiling, and to object at any time to direct marketing; receive personal information you provided to us in a structured, commonly used, machine-readable format and have it transmitted to another controller where technically feasible; withdraw consent at any time where we rely on consent, without affecting processing that took place before withdrawal; not be subject to a decision based solely on automated processing that produces legal or similarly significant effects, except where permitted by law, and to obtain human intervention as described in Section 5; and lodge a complaint with a supervisory authority, in particular in the country of your habitual residence, place of work or the place of the alleged infringement. We would appreciate the chance to address your concerns first.

12.3 California and other US state rights. If you are a resident of California or another US state with a comprehensive privacy law, you may have the right to know what personal information we collect, use, disclose and share, to access it, to correct it, to delete it, to receive a portable copy, to opt out of the sale of your personal information and of sharing for cross-context behavioral advertising or targeted advertising, to limit the use of sensitive personal information, and not to be discriminated against for exercising your rights. We do not sell personal information. [If we use advertising pixels, our use of them may be considered "sharing" under California law; you can opt out using the "Do Not Sell or Share My Personal Information" link on the Platform or by enabling Global Privacy Control in your browser.] In the preceding twelve months we have collected the categories of personal information described in Section 3, used them for the purposes described in Section 4, and disclosed them to the categories of recipients described in Section 6. You may designate an authorized agent to make a request on your behalf; we will require proof of the agent's authority and may require you to verify your identity directly.

12.4 Limits on deletion and other rights. We may decline or limit a request where the law allows us to, and in particular we will keep information where we need it: to comply with legal obligations, including tax, anti-money-laundering and gaming record-keeping requirements; to honor a self-exclusion or a ban, which requires us to retain the identifiers needed to recognize you and prevent evasion; to complete a transaction, resolve a dispute, or investigate or recover from an Exploit, fraud or breach of the Terms; to establish, exercise or defend legal claims; or for security. Deleting your Account does not delete information that has been written to the blockchain, information that other users have already seen, or information in backups until those backups are cycled.

12.5 How to exercise your rights. Use the controls in your Account where available, or email privacy@stonksino.xyz from your registered email address. To protect your Account we will verify requests, which may include asking you to sign a message from your connected wallet or to confirm from your registered email. We respond within the time required by applicable law, generally within thirty (30) days, and we will tell you if we need longer. We do not charge for requests unless they are manifestly unfounded or excessive.

13. CHILDREN

The Platform is for adults only. We do not knowingly collect personal information from anyone under eighteen (18) years old or under the legal gambling age in their jurisdiction. If we learn that a person under the applicable age has created an Account, we will close it, void winnings and handle deposits as described in the Terms, and delete the person's information except where we must keep it to enforce the exclusion or comply with law. If you believe a minor has used the Platform, please contact us at privacy@stonksino.xyz.

14. THIRD-PARTY LINKS AND SERVICES

The Platform contains links to wallets, block explorers, token launchpads, decentralized exchanges and swap aggregators, social media platforms, token pages and other third-party services. When you connect a wallet, the wallet provider may collect information about your interaction with the Platform under its own privacy policy. We are not responsible for the privacy practices of any third party, and we encourage you to read their policies.

15. DATA PROTECTION CONTACTS

Privacy requests and questions: privacy@stonksino.xyz
Security reports: security@stonksino.xyz
Postal address: [OPERATOR ENTITY], [REGISTERED ADDRESS]
[Data protection officer: [•]]
[EU representative under Article 27 GDPR: [•]]
[UK representative under Article 27 UK GDPR: [•]]

16. CHANGES TO THIS POLICY

We may update this Policy from time to time. When we make a material change we will post the updated Policy on the Platform with a new "Last updated" date and, where reasonably practicable, notify you by a notice on the Platform or by email before the change takes effect. Your continued use of the Platform after the change takes effect means that you accept the updated Policy, to the extent permitted by law. Where a change requires your consent we will ask for it.

By using Stonksino you confirm that you have read and understood this Privacy Policy.