PUMPLYX LABS LTD. is an independent
development studio
specializing in next-generation gaming.

Privacy Policy

Welcome to Pumplyx!

By accessing, browsing, registering, or otherwise making use of the Platform in any capacity, operated by Pumplyx Labs Ltd. a company registered under the laws of the British Virgin Islands, with company registration number 2174285 and registered office at Intershore Chambers, Road Town, Tortola, British Virgin Islands, you confirm that you are aware of the purposes and methods of collecting and processing personal data. You also consent to the processing of your personal data by Pumplyx Labs Ltd. and the authorized third parties specified in this Privacy Policy.

If you do not agree with this Privacy Policy, you must immediately stop using the Platform.

I. General Provisions

  1. This privacy policy (“Privacy Policy”) sets out how Pumplyx Labs Ltd. (“we,” “us,” “our”) collects, uses, stores, and processes personal data from users (“you,” “your”) in connection with your use of the Pumplix platform (“Platform”) and related services.
  2. We reserve the right to change the Privacy Policy from time to time, so we ask you kindly to regularly check the current version of the Privacy Policy.
  3. We comply with all rules regarding the collection, processing, and storage of personal data as set out in this Privacy Policy. If you do not agree with the Privacy Policy, please leave the Platform and do not use our services.
  4. You can withdraw your consent at any time. Such withdrawal of consent would not affect the lawfulness of data processing done prior to the withdrawal of consent. Where such withdrawal of consent would prevent us from providing services to you, we will endeavor to inform you.
  5. We do not collect or process data relating to race, political positions, religious beliefs, or membership in political organizations.
  6. Our Platform is intended solely for individuals who are at least 18 (eighteen) years old. By accessing or using the Platform, you represent and warrant that you are 18 (eighteen) years of age or older. If you are under the age of 18 (eighteen), please exit and refrain from using the Platform immediately.
  7. We do not knowingly collect, use, or process data from individuals under the age of 18 (eighteen), and we disclaim any liability for any use of the Platform by persons who have not reached the age of 18 (eighteen).
  8. This Privacy Policy applies to all users of the Platform, regardless of your country of residence, nationality, or legal jurisdiction. By using the Platform, you consent to the terms and conditions for processing your personal data in accordance with this Privacy Policy.

II. Personal Data

  1. We typically collect or obtain your personal data because you provide it directly to us through registration, interactions with the Platform, or by linking external accounts. Additionally, we may receive personal data from third-party service providers that assist in operating the Platform, such as blockchain networks, or analytics tools.
  2. We only collect and process personal data that is necessary to provide you with our services and to comply with legal obligations imposed on us by applicable law. This includes, without limitation, the following categories of personal data:
    • Email address;
    • Username;
    • IP address;
    • Cryptocurrency wallet and transactions data;
    • Platform activity logs (including task completion history, transactions, and engagement analytics);
    • Device and browser data, including cookies.
  3. In some cases, we may also collect personal data about you indirectly from third parties including but not limited to third-party service providers assisting with analytics, fraud prevention, and security, blockchain networks for transaction verification, and government authorities if required by law.
  4. You are able to change your personal account data on the Platform by submitting new information.
  5. We may also collect and process data contained in your feedback, comments, appeals, complaints, requests, or grievances sent to our support email.

III. Cookies

  1. Cookies and similar tracking technologies are used to enhance user experience, improve Platform functionality, and analyze user interactions. A cookie is a small piece of data stored on a user’s device that allows the Platform to remember information about the user’s preferences, login details, and browsing activity. These technologies enable us to optimize our services, personalize content, and prevent fraudulent activities.
  2. We (or authorized third-party analytics providers) may use cookies and other tracking tools to collect and process user activity data. This includes, but is not limited to, tracking session duration, login attempts, interaction with Platform features, and engagement with advertisements. Some cookies are session-based (deleted after closing the browser), while others are persistent (remain stored on the device for a set period).
  3. The types of cookies used on the Platform include:
    • Necessary cookies – Essential for the core functionality of the Platform, including security, fraud prevention, and session management. Without these cookies, the Platform may not function properly;
    • Functional cookies – Improve user experience by remembering settings, preferences, and customization choices (e.g., language selection);
    • Analytical cookies – Help us understand user behavior, measure Platform performance, and optimize the user experience.
    • Advertising cookies – Used by third-party advertising networks to track user activity across websites and display targeted ads based on interests and interactions.
  4. Some tracking technologies may collect additional data, such as device type, operating system, and geolocation (if enabled). These methods help prevent unauthorized access, detect fraudulent behavior, and provide better security measures.
  5. Users can control or disable cookies through their browser settings. However, disabling certain cookies may affect Platform performance and limit access to certain features. Users are informed about cookie usage via an on-screen banner and may manage their preferences upon their first access to the Platform.
  6. Cookies that store personal data are automatically deleted after a defined period, depending on their function. Session cookies expire when the browser is closed, while persistent cookies have a retention period of up to 12 months unless manually deleted by the user.

IV. Data Usage

  1. Pumplyx Labs Ltd. collects and processes personal data to ensure the proper operation of the Platform, deliver services, comply with legal requirements, safeguard our rights and interests (as well as those of users and third parties), and detect and prevent malicious or fraudulent activities. Specifically, data is processed for the following purposes:
    • Providing, maintaining, and optimizing Platform functionality, ensuring seamless performance and user experience;
    • Processing transactions, including reward distribution based on user participation in activities;
    • Enhancing security, fraud prevention, and user verification, including authentication procedures, blockchain transaction validation, and detection of unauthorized activities;
    • Performing analytics and tracking engagement to improve Platform efficiency, user retention, and feature development;
    • Facilitating marketing campaigns;
    • Complying with legal and regulatory requirements applicable to platforms using blockchain technology.
  2. Personal data is processed in alignment with applicable data protection laws, ensuring that no excessive or irrelevant data is collected beyond what is necessary for the stated purposes.
  3. Data may also be used in anonymized and aggregated formats for research, service improvements, and internal statistical analysis. Such anonymized data does not contain personally identifiable information.

V. Legal Grounds

  1. The processing of personal data is carried out on the following lawful grounds:
    • User Consent. Personal data is processed based on the user’s voluntary, informed, and explicit consent at the time of registration, when linking external accounts, or engaging with specific features. Consent is recorded via Platform registration logs and/or blockchain transaction metadata. Users can withdraw consent at any time, but this may impact their ability to access certain services.
    • Performance of contractual obligations. Data is processed to fulfill our contractual commitments, such as providing Platform services and executing transactions within the blockchain system.
    • Legal Compliance. Pumplyx Labs Ltd. processes personal data to meet legal and regulatory obligations, particularly those related to blockchain transactions, fraud prevention, and compliance with international data protection laws;
    • Protection of rights, vital interests, and legitimate interests. Data is processed to protect the security, integrity, and functionality of the Platform, ensuring the rights and interests of users, preventing fraudulent activities, and complying with legal enforcement requests when necessary.

VI. Data Transfer to Third Parties

  1. Pumplyx Labs Ltd. may share user personal data with third parties when necessary to operate the Platform, ensure compliance with applicable laws, maintain security, prevent fraud, and enhance user experience. The following categories of third parties may receive personal data:
    • Affiliated companies and ecosystem partners involved in the development, integration, and expansion of the Pumplyx Labs Ltd. Platform;
    • Technical and IT service providers, including cloud storage providers, blockchain infrastructure operators, and cybersecurity firms that support Platform functionality and data security;
    • Marketing and analytics services, including third-party tools like Google Analytics, Branch.io and Firebase, which help monitor user engagement and track performance, as well as optimize platform features;
    • Fraud prevention, risk management, and security firms that help detect unauthorized activities, prevent system abuse, and protect user accounts;
    • Regulatory bodies, law enforcement agencies, or legal authorities if disclosure is required under applicable laws, court orders, or formal government requests;
    • Potential investors, acquirers, or business partners in the event of a merger, acquisition, or corporate restructuring of Pumplyx Labs Ltd. provided that appropriate data protection measures are in place.
  2. Pumplyx Labs Ltd. does not sell or rent personal data to third parties. All data sharing is conducted strictly in accordance with this Privacy Policy and relevant legal frameworks.
  3. If Pumplyx Labs Ltd. is required to disclose personal data in response to a law enforcement request, regulatory inquiry, or legal obligation, such disclosure will be carefully reviewed to ensure compliance with applicable laws while safeguarding user rights and privacy.
  4. If Pumplyx Labs Ltd. transfers personal data outside the user's country of residence, appropriate safeguards are implemented.

Pumplyx Labs Ltd. does not control third-party websites, blockchain networks, or decentralized applications linked to the Platform. Users are responsible for reviewing the privacy policies of third-party services before interacting with them. Pumplyx Labs Ltd. is not liable for unauthorized data collection, leaks, or breaches caused by external services integrated into the Platform.

VII. Data Retention

  1. Pumplyx Labs Ltd. stores user personal data on secure cloud-based servers, decentralized blockchain networks, and encrypted storage solutions. Some data may be retained in off-site backups or secure network-accessible storage, which is restricted to authorized personnel only. By providing personal data, users agree to its transfer, storage, and processing under this Privacy Policy.
  2. Security Measures: Pumplyx Labs Ltd. implements industry-standard technical and organizational measures to protect stored user data against unauthorized access, loss, or destruction. These measures include:
    • Utilizing Cloudflare for network security, including protection against Distributed Denial of Service (DDoS) attacks and malicious traffic filtering;
    • Employing Amazon Web Services (AWS) for secure, encrypted data storage with high availability, redundancy, and disaster recovery capabilities.

However, users acknowledge that no data transmission over the Internet or blockchain can be entirely secure, and Pumplyx Labs Ltd. cannot fully guarantee the security of personal information transmitted to the Platform. Users should take additional security measures and securing their blockchain wallets.

  1. Personal data is deleted or anonymized under the following conditions:
    • The data is no longer required for the purposes for which it was collected or processed;
    • The user withdraws consent or objects to processing, and no overriding legal basis exists to continue storing it;
    • The data was unlawfully collected or processed in violation of applicable laws;
    • Pumplyx Labs Ltd. is required to delete the data by regulatory or legal directives.
  2. Retention periods for personal data vary based on regulatory requirements, security needs, and operational purposes. Pumplyx Labs Ltd. retains data as follows:
    • Blockchain transaction data – Permanently stored on decentralized ledgers and cannot be altered or deleted;
    • User account data – Stored for the duration of the account’s existence and deleted upon user request, unless required for legal or security reasons; may also be deleted earlier or retained longer in accordance with the company’s internal data management policies;
    • Customer support inquiries – Retained for up to 3 years after issue resolution, unless deleted earlier or retained longer in accordance with the company’s internal data management policies;
    • Fraud and security-related logs – Retained for up to 5 years for risk assessment and fraud prevention; may be deleted earlier or retained longer in accordance with the company’s internal data management policies;
    • Marketing and engagement data – Retained for up to 12 months unless the user opts out; may be deleted earlier or retained longer in accordance with the company’s internal data management policies.
  3. Users acknowledge that participation in blockchain-based reward systems involves inherent data-related risks, including but not limited to the permanence and public nature of blockchain transactions, the decentralized and irreversible structure of data storage, and potential changes in legal or regulatory frameworks governing blockchain technologies.
  4. Users are solely responsible for maintaining the security of their account credentials, blockchain wallets, and access tokens. Any unauthorized access caused by negligence (e.g., weak passwords, phishing attacks) is the user’s responsibility. Pumplyx Labs Ltd. strongly recommends using strong passwords, enabling multi-factor authentication, and keeping private keys secure.

VIII. User Rights

  1. Right of Access: Users have the right to request access to their personal data, including obtaining a copy of stored information.
  2. Right to Information: Users have the right to request information about:
    • The purposes of data processing;
    • The categories of personal data collected;
    • The recipients (or categories of recipients) with whom personal data is shared, including those in third countries;
    • The expected retention period of the data or the criteria used to determine that period;
    • Any automated decision-making, including profiling, and its potential impact on users.
    • Other rights as defined by applicable data protection laws;
  3. Right to Rectification: Users can request corrections or updates to inaccurate, outdated, or incomplete personal data.
  4. Right to Erasure (Right to be Forgotten): Users can request the deletion of their personal data in whole or in part, particularly if:
    • The data is no longer necessary for its original purpose;
    • The user withdraws consent and there is no legal reason to retain the data;
    • The data has been unlawfully processed;
    • The user objects to processing, and no overriding legitimate grounds exist for continuing storage.
  5. Right to Withdraw Consent: Users can withdraw their consent for data collection and processing at any time. However, withdrawing consent may affect access to certain features or Platform functionalities.
  6. Right to File Complaints: Users can file complaints regarding data collection, processing, or security concerns. Pumplyx Labs Ltd. will address such complaints in compliance with applicable data protection regulations.
  7. Users can exercise any of their rights by contacting Pumplyx Labs Ltd. support team at info@pumplyx.com.

IX. Final Provisions

  1. We respect your rights regarding any issues related to the collection and processing of personal data, ensuring that any requests you make are dealt with promptly and transparently.
  2. We do not guarantee the error-free operation of the Platform in accordance with the Privacy Policy. We use reasonable efforts to comply with the Privacy Policy and shall not be liable for any incidental, direct or consequential damages arising from your use of the Platform.
  3. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your personal data, we shall within 120 hours of having knowledge of such breach report the details of the breach to the appropriate government agency.
  4. Where we ascertain that such breach is detrimental to your rights and freedoms in relation to your personal data, we shall within 10 days of knowledge of the occurrence of such breach take steps to inform you of the breach incident, the risk to your rights resulting from such breach and any course of action to remedy said breach.
  5. In the event of any conflict or inconsistency between the English version of this Privacy Policy and any translated versions, the English version shall prevail.
  6. For any questions arising from the collection and processing of your personal data, you may contact us by email at info@pumplyx.com.