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SBARTER LIMITED PRIVACY POLICY

Last Updated: February 2026

1. INTRODUCTION

This Privacy Policy describes how Sbarter Limited (“Sbarter”, “We”, “Us”), a company incorporated in Malta, collects, uses, and shares your information when you use our mobile application and platform (the “Services”).We operate on a principle of Data Minimization, collecting only the absolute minimum information necessary to secure your account and ensure legal compliance.

2. DATA WE COLLECT

We collect only the following specific categories of data directly from you:

Authentication Data

  • Email Address and/or Phone Number used for account creation, logging in and account recovery.

Eligibility & Compliance Data

  • Date of Birth: To ensure you meet the minimum age requirements (18+).
  • Country and State of Residence: To ensure you are not located in a prohibited jurisdiction (e.g., restricted US states or sanctioned countries).

Technical & Blockchain Data

  • Public Wallet Address: Your public blockchain address is used to facilitate transactions.
  • Device Information: We may collect device IDs or IP addresses solely for security purposes and to enforce geographic restrictions (Geoblocking).

Reputation Data (Integrity Score)

We automatically process data related to your historical reliability in Competitions to generate an algorithmic Integrity Score. This includes records of Validated and Non-Validated Matches.

3. HOW VERIFICATION WORKS

We utilise a Decentralized Identity model for “Know Your Customer” (KYC) verification :

  • Third-Party Provider: You submit your identity documents directly to our independent provider, SumSub.
  • Verification Status: Once verified, a cryptographic token is issued to your Wallet. Sbarter uses this “Verified” status to operate the platform features.
  • Administrative Access: While Sbarter does not store these documents on its own servers, we retain administrative access to view the underlying documents via the SumSub dashboard for legal compliance and audit purposes.

4. HOW WE USE YOUR DATA

We use the limited data we collect for the following purposes:

  • Service Operation: To facilitate peer-to-peer competitions, execute Smart Contracts, and calculate Integrity Scores.
  • Account Access: To authenticate your identity when you log in via email or phone.
  • Legal Compliance: To block access to the Services if you are underage or located in a prohibited jurisdiction (including restri9cted US states).
  • On-Ramp Services: If you choose to use third-party on-ramp services to acquire tokens via our platform, we may share your KYC data directly with the payment provider to facilitate the transaction.
  • Security: To detect multi-accounting, fraud, or location spoofing (VPNs).

5. DISCLOSURE OF YOUR INFORMATION

We do not sell your personal data. We may share your data only in the following limited circumstances:

  • Service Providers: We use trusted third-party cloud providers (e.g., Firebase/AWS) and our KYC provider, SumSub.
  • Payment Providers: Third-party on-ramp services, if explicitly requested by you to facilitate token acquisition.
  • Legal Requirements: We may disclose your Email/Phone, Age, or Country if strictly required by law, court order, or governmental authority.

6. BLOCKCHAIN TRANSPARENCY

Please be aware that blockchain transactions are public and immutable. Your Wallet Address and Transaction History are permanently recorded on the Solana blockchain. Sbarter cannot delete, hide, or modify this onchain data.

7. DATA RETENTION & DELETION

  • Retention: We retain off-chain your Email/Phone, Date of Birth, Country and compliance data only as long as your User Account is active.
  • Deletion: You may request the deletion of your account and associated off-chain personal data at any time through the App settings.
  • Limitations: Deletion of your account does not remove your historic transaction data from the blockchain. Deletion may be delayed if your account is under investigation for a breach of our Fair-Play Policy or other misconduct.

8. YOUR RIGHTS (GDPR & CCPA)

Depending on your location, you have the right to:

  • Access: Request a copy of the specific personal data we hold about you.
  • Correction: Update your email, phone, or residence if it changes.
  • Deletion: Request the erasure of your personal data from our servers (“Right to be Forgotten”), subject to the blockchain limitations noted above.

9. CONTACT US

If you have questions about this Privacy Policy or wish to exercise your data rights, please contact us at: support@sbarter.com