1. Introduction

Welcome to Bull Crypto Run. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our mobile application and website (collectively, the "Service").

This policy is designed to comply with applicable privacy and data protection laws worldwide, including but not limited to:

• GDPR — General Data Protection Regulation (European Union / EEA)
• UK GDPR — United Kingdom General Data Protection Regulation
• CCPA / CPRA — California Consumer Privacy Act / California Privacy Rights Act (USA)
• LGPD — Lei Geral de Proteção de Dados (Brazil)
• PIPEDA — Personal Information Protection and Electronic Documents Act (Canada)
• POPIA — Protection of Personal Information Act (South Africa)
• PDPA — Personal Data Protection Act (Singapore, Thailand)
• APPI — Act on Protection of Personal Information (Japan)
• Privacy Act 1988 (Australia)
• And other applicable local data protection laws

By accessing or using the Service, you agree to this Privacy Policy. If you do not agree, please discontinue use of the Service.

2. Data Controller

The data controller responsible for your personal data is:

Bull Crypto Run
Email: contact@bullcryptorun.com

If you have any questions about this Privacy Policy or wish to exercise your data rights, please contact us at the email address above.

3. Information We Collect

3.1 Information You Provide

• Wallet Address: Your Solana public wallet address when you connect your wallet to the Game.
• Game Data: Tournament scores, game results, entry fee selections, and leaderboard rankings.
• Language Preferences: Your selected language within the application.
• Support Communications: Any information you provide when contacting us for customer support.

3.2 Information Collected Automatically

• Device Information: Device model, operating system version, unique device identifiers, and mobile network information.
• Usage Data: App interaction data, gameplay statistics, session duration, feature usage, and crash logs.
• Blockchain Transaction Data: On-chain transaction records related to tournament entry fees, prize distributions, and wallet interactions (note: blockchain data is inherently public).

3.3 Information We Do NOT Collect

• We do not collect your name, email address, phone number, or physical address (unless you voluntarily provide them for support).
• We do not collect your private keys, seed phrases, or wallet passwords.
• We do not access your precise geolocation.
• We do not access your camera, microphone, contacts, or files.

4. How We Use Your Information

We use the collected information for the following purposes:

Purpose	Legal Basis (GDPR)
Operate and provide the Game service	Contract performance
Process tournament entries and prize distributions	Contract performance
Display leaderboard rankings	Legitimate interest
Detect and prevent fraud, cheating, and abuse	Legitimate interest
Improve the Game, fix bugs, and optimize performance	Legitimate interest
Comply with legal obligations	Legal obligation
Respond to support requests	Legitimate interest / contract

5. Blockchain and Public Data

Bull Crypto Run operates on the Solana blockchain. Please be aware of the following:

• Your wallet address and transaction history (including tournament entries, scores submitted on-chain, and prize payouts) are recorded on the Solana blockchain, which is publicly accessible and permanent.
• We have no ability to delete, modify, or restrict access to data stored on the blockchain.
• Leaderboard rankings using wallet addresses may be visible to other players within the Game.
• If you wish to maintain anonymity, you should use a wallet address not linked to your real-world identity.

6. Data Sharing and Disclosure

We do not sell your personal data to third parties. We may share information in the following limited circumstances:

• Blockchain Network: Transaction data is broadcast to the Solana network as required for the Game to function.
• Service Providers: We may use trusted third-party service providers (e.g., hosting, analytics) who process data on our behalf under strict data processing agreements.
• Legal Requirements: When required by law, regulation, court order, or governmental request.
• Safety: To protect the rights, property, or safety of our users, ourselves, or the public.
• Business Transfers: In connection with a merger, acquisition, or sale of assets, your data may be transferred as part of the transaction, subject to standard confidentiality obligations.

7. International Data Transfers

As a globally available service, your data may be processed in countries outside your country of residence, which may have different data protection laws. When we transfer data internationally, we implement appropriate safeguards, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Data processing agreements with all third-party processors
• Encryption of data in transit and at rest
• Compliance with applicable international transfer mechanisms

8. Data Retention

• Game Data: We retain gameplay data (scores, rankings, tournament history) for as long as your account/wallet is active and for a reasonable period thereafter for analytics and dispute resolution.
• Device and Usage Data: Retained for up to 24 months, then anonymized or deleted.
• Support Communications: Retained for up to 36 months after the issue is resolved.
• Blockchain Data: Data stored on the Solana blockchain is permanent and cannot be deleted by us or any party.

9. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

9.1 Universal Rights

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate personal data.
• Deletion: Request deletion of your personal data (subject to legal obligations and blockchain limitations).
• Objection: Object to certain processing activities based on legitimate interests.
• Data Portability: Receive your data in a structured, commonly used, and machine-readable format.
• Withdraw Consent: Where processing is based on consent, withdraw your consent at any time.

9.2 European Union / EEA / UK Residents (GDPR / UK GDPR)

You have the right to lodge a complaint with your local Data Protection Authority (DPA). You also have the right to restrict processing and not be subject to automated decision-making.

9.3 California Residents (CCPA / CPRA)

You have the right to:

• Know what personal information is collected and how it is used
• Request deletion of your personal information
• Opt-out of the sale of personal information (we do not sell personal information)
• Non-discrimination for exercising your privacy rights
• Correct inaccurate personal information
• Limit the use of sensitive personal information

9.4 Brazilian Residents (LGPD)

Under the LGPD, you have the right to confirmation of data processing, data access, correction, anonymization, portability, deletion, and information about shared data. You may file a complaint with the ANPD (Autoridade Nacional de Proteção de Dados).

9.5 Canadian Residents (PIPEDA)

You have the right to access your personal information, challenge its accuracy, and withdraw consent for its collection, use, or disclosure. Complaints may be filed with the Office of the Privacy Commissioner of Canada.

9.6 Other Jurisdictions

If you reside in a jurisdiction with additional data protection rights (e.g., Australia, Japan, South Korea, Singapore, South Africa, Thailand), we respect and uphold those rights in accordance with local law. Contact us for jurisdiction-specific inquiries.

To exercise any of your rights, contact us at: contact@bullcryptorun.com. We will respond within 30 days (or the timeframe required by your local law).

10. Data Security

We implement industry-standard security measures to protect your data, including:

• Encrypted storage of sensitive data using AES-256 and secure key management
• TLS/SSL encryption for all data transmitted between the App and our servers
• Secure wallet integration through established Solana wallet adapters (we never access or store your private keys)
• Regular security audits and code reviews
• Anti-tampering and code obfuscation protections in production builds

Despite these measures, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your data.

11. Children's Privacy

Bull Crypto Run is not intended for individuals under the age of 18 (or the age of majority in your jurisdiction, whichever is higher).

We do not knowingly collect personal data from children. The Game involves cryptocurrency transactions, which require users to be of legal age in their respective jurisdictions.

If we learn that we have collected personal data from a child, we will take immediate steps to delete that information. If you believe a child has provided us with personal data, please contact us at contact@bullcryptorun.com.

12. Cookies and Tracking Technologies

Website: Our website may use essential cookies to ensure functionality and optional analytics cookies to understand traffic patterns. You can control cookie preferences through your browser settings.

Mobile Application: The App uses local storage (Shared Preferences and Secure Storage) to save your language preferences and encrypted session data. This data remains on your device and is not transmitted to third parties.

13. Third-Party Services

The Game interacts with the following third-party services:

• Solana Blockchain: For on-chain tournament management, entry fees, score submission, and prize distribution. Governed by the Solana network's decentralized protocol.
• Solana Wallet Provider: The Game connects to your chosen Solana wallet app (e.g., Phantom, Solflare). Please refer to your wallet provider's own privacy policy.
• App Stores: The Game is distributed via Google Play Store and Apple App Store. Their respective privacy policies apply to download and installation.

We are not responsible for the privacy practices of third-party services. We recommend reviewing their privacy policies independently.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes:

• We will update the "Last updated" date at the top of this page.
• For significant changes, we will provide notice within the Game or on our website.
• Your continued use of the Service after any changes constitutes acceptance of the updated policy.

15. Governing Law and Dispute Resolution

This Privacy Policy is governed by Brazilian law. Any disputes arising from this policy that cannot be resolved amicably will be submitted to the competent courts of Brazil, without prejudice to any mandatory consumer protection rights applicable in your country of residence.

For residents of the EU/EEA, nothing in this policy affects your rights under EU law to bring proceedings before the courts or data protection authorities of the EU Member State in which you reside.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at:

Bull Crypto Run
Email: contact@bullcryptorun.com
Website: bullcryptorun.com

We are committed to resolving any complaints about your privacy and our collection or use of your personal information. We aim to respond to all requests within 30 days.