X3NA — Privacy Policy

1. Introduction

1.1 Who We Are

XENA.COM ("we," "us," "our") operates the X3NA platform, a skill-based prediction competition platform built on BASE blockchain. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use our Platform.

1.2 What This Policy Covers

This Privacy Policy applies to all information collected through the X3NA platform, website, and related services (collectively, the "Platform"). It describes our practices regarding information collection, use, and disclosure.

1.3 Our Privacy Commitment

We are committed to protecting your privacy. We collect minimal data necessary to operate the Platform and do not require identity verification (KYC) or collection of personally identifiable information beyond what is technically necessary.

1.4 Governing Law

This Privacy Policy is governed by the laws of the Republic of Estonia. For users in the European Economic Area (EEA), this Policy also complies with the General Data Protection Regulation (GDPR). For California residents, this Policy complies with the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

2. Information We Collect

2.1 Wallet Information

When you connect your wallet to the Platform, we collect your wallet address. This is necessary to process transactions and provide Platform services. Your wallet address serves as your Platform identifier.

2.2 On-Chain Data

All transactions on BASE blockchain are public and permanent. We may access and analyze on-chain data related to your wallet address, including transaction history, prediction entries, and distributions. This data is publicly available on the blockchain.

2.3 Analytics Data

We collect analytics data to understand how users interact with the Platform. This may include:

• Page views and navigation patterns
• Device information (browser type, operating system)
• IP address (anonymized where possible)
• Referral source
• Platform usage statistics

2.4 Communications Data

If you contact us via email or other communication channels, we collect the information you provide, including your email address and message content. We use this information to respond to your inquiries.

2.5 Information We Do NOT Collect

We do NOT collect:

• Personal identification information (name, address, phone)
• Identity verification documents (KYC)
• Financial account information beyond wallet addresses
• Biometric data
• Location data beyond IP address
• Social media account information

3. How We Use Your Information

3.1 Platform Operation (Contract Performance)

We use your information to:

• Process predictions and transactions
• Distribute rewards to winners
• Maintain your Platform activity history
• Provide customer support
• Enforce Platform rules and Terms of Use

3.2 Platform Improvement (Legitimate Interests)

We use analytics data to:

• Improve Platform functionality and user experience
• Identify and fix technical issues
• Analyze usage patterns to enhance features
• Develop new Platform capabilities

3.3 Security and Fair Competition (Legitimate Interests)

We use information to:

• Detect and prevent fraud, abuse, and violations
• Monitor Platform integrity
• Prevent multi-accounting and collusion
• Ensure fair competition
• Protect Platform and user security

3.4 Legal Compliance (Legal Obligation)

We may use and disclose information as required by applicable laws, regulations, or legal processes, including responding to lawful requests from government authorities.

3.5 With Your Consent

We may use your information for other purposes with your explicit consent. You can withdraw consent at any time by contacting us.

4. Blockchain Transparency

4.1 Public Nature of Blockchain

All transactions on BASE blockchain are public and permanent. Your wallet address and transaction history are visible to anyone with access to blockchain data. This transparency is inherent to blockchain technology and cannot be changed.

4.2 Off-Chain Data

We store minimal off-chain data necessary for Platform operation, such as analytics data and communication records. This data is stored securely and is not publicly accessible.

4.3 Immutability Disclosure

Once data is recorded on the blockchain, it cannot be deleted or modified. This means your transaction history is permanent and cannot be erased, even if you request deletion of your data.

4.4 Pseudonymity

While blockchain transactions are public, wallet addresses are pseudonymous. Your wallet address does not directly reveal your identity unless you choose to link it to your identity through other means.

5. Third-Party Services

5.1 Analytics Providers

We use third-party analytics services to understand Platform usage. These services may collect information about your use of the Platform. We use analytics providers that prioritize privacy and data protection.

5.2 Blockchain Infrastructure

The Platform operates on BASE blockchain, which is maintained by third-party infrastructure providers. Your interactions with the blockchain are subject to the policies and practices of these providers.

5.3 Data Sharing Principles

We do not sell your personal information. We only share information with third parties:

• As necessary to provide Platform services
• With your explicit consent
• As required by law or legal process
• To protect Platform security and integrity

6. International Data Transfers

6.1 Where Your Data May Be Processed

Your information may be processed and stored in countries outside your country of residence, including the European Economic Area (EEA). We ensure appropriate safeguards are in place for such transfers.

6.2 Blockchain-Specific Transfers

Blockchain data is distributed globally across network nodes. This means your on-chain data may be stored and processed in multiple jurisdictions worldwide. This is inherent to blockchain technology and cannot be controlled by us.

6.3 Safeguards for Non-EU Transfers

For transfers of personal data outside the EEA, we rely on appropriate safeguards such as standard contractual clauses or adequacy decisions by the European Commission.

7. Data Retention

7.1 Retention Periods

We retain your information for as long as necessary to:

• Provide Platform services
• Comply with legal obligations
• Resolve disputes and enforce agreements
• Maintain Platform security and integrity

Analytics data is typically retained for up to 2 years. Communication records are retained for up to 3 years.

7.2 After Retention Period

After the retention period expires, we delete or anonymize your information, except for blockchain data, which is permanent and cannot be deleted.

7.3 Deletion Requests

You may request deletion of your off-chain data by contacting us. However, we cannot delete blockchain data, as it is permanent and immutable. We will delete off-chain data to the extent possible while maintaining necessary records for legal compliance and Platform operation.

8. Your Privacy Rights

8.1 Rights for All Users

All users have the right to:

• Access information we hold about you
• Request correction of inaccurate information
• Request deletion of off-chain data (subject to limitations)
• Object to processing of your information
• Request restriction of processing
• Data portability (where applicable)

8.2 Rights for EEA Residents (GDPR)

If you are located in the EEA, you have additional rights under GDPR:

• Right to erasure ("right to be forgotten") — subject to blockchain limitations
• Right to object to processing
• Right to data portability
• Right to withdraw consent
• Right to lodge a complaint with a supervisory authority

8.3 Right to Erasure Limitations

Due to the immutable nature of blockchain technology, we cannot delete on-chain data. We can only delete off-chain data to the extent permitted by law and necessary for Platform operation.

8.4 Automated Decision-Making

The Platform uses automated systems for processing predictions and distributing rewards. You have the right to request human review of automated decisions that significantly affect you.

8.5 How to Exercise Your Rights

To exercise your privacy rights, contact us at x3na.io.notion@gmail.com with the subject line "Privacy Rights Request — [Your Request Type]". We will respond within 30 days (or as required by applicable law).

8.6 Right to Lodge a Complaint

If you are located in the EEA and believe we have violated your privacy rights, you have the right to lodge a complaint with your local data protection authority.

9. Your California Privacy Rights

9.1 CCPA/CPRA Applicability

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

9.2 Categories of Personal Information

We collect the following categories of personal information:

• Identifiers: Wallet addresses, IP addresses (anonymized where possible)
• Internet activity: Platform usage, analytics data, browsing patterns
• Transaction data: On-chain transaction history (publicly available)

9.3 Your California Rights

California residents have the right to:

• Know what personal information we collect
• Know whether we sell or share personal information (we do not)
• Access their personal information
• Request deletion of personal information (subject to limitations)
• Correct inaccurate personal information
• Opt-out of sale or sharing of personal information
• Limit use of sensitive personal information
• Non-discrimination for exercising privacy rights

9.4 How to Submit a Request

To exercise your California privacy rights, contact us at x3na.io.notion@gmail.com with the subject line "California Privacy Request — [Your Request Type]". We will verify your identity before processing your request.

9.5 Notice of Financial Incentives

We offer a referral program that provides rewards. Participation is voluntary and does not require you to provide additional personal information beyond what is necessary for Platform operation.

10. Cookies and Tracking Technologies

10.1 What Are Cookies

Cookies are small text files stored on your device when you visit websites. We use cookies and similar technologies to enhance your experience and analyze Platform usage.

10.2 Types of Cookies We Use

We use the following types of cookies:

• Essential cookies: Required for Platform functionality
• Analytics cookies: Help us understand how users interact with the Platform
• Preference cookies: Remember your settings and preferences

10.3 Your Cookie Choices

You can control cookies through your browser settings. However, disabling certain cookies may affect Platform functionality.

10.4 More Information

For more information about cookies and how to manage them, visit www.allaboutcookies.org.

11. Data Security

11.1 Technical Measures

We implement technical and organizational measures to protect your information, including:

• Encryption of data in transit
• Secure storage of off-chain data
• Access controls and authentication
• Regular security assessments

11.2 Smart Contract Security

Our smart contracts are audited and tested for security vulnerabilities. However, no system is completely secure, and we cannot guarantee absolute security.

11.3 Your Security Responsibilities

You are responsible for:

• Maintaining the security of your wallet and private keys
• Using secure devices and networks
• Not sharing your wallet credentials
• Reporting security issues to us

11.4 Security Incidents

In the event of a security incident affecting your personal information, we will notify you and relevant authorities as required by law.

12. Platform Integrity Monitoring

12.1 Fair Competition

We monitor Platform activity to ensure fair competition and prevent fraud, abuse, and violations of our Terms of Use.

12.2 How We Monitor

We use automated systems and manual review to:

• Detect multi-accounting and collusion
• Identify suspicious patterns
• Prevent automated bot activity
• Ensure compliance with Platform rules

12.3 Consequences

Violations may result in warnings, suspension, or permanent ban from the Platform. We may also forfeit rewards and take legal action where appropriate.

12.4 Your Rights

You have the right to appeal decisions and request information about monitoring activities affecting you, subject to security and legal limitations.

13. Children's Privacy

13.1 Age Requirement

The Platform is not intended for users under 18 years of age (or the age of majority in your jurisdiction). We do not knowingly collect personal information from children.

13.2 If We Discover Underage Use

If we discover that we have collected information from a child under 18, we will delete that information immediately and suspend the associated account.

13.3 Parental Notification

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

14. Changes to This Policy

14.1 How We Update

We may update this Privacy Policy from time to time. When we make changes, we will:

• Update the "Last Updated" date
• Notify you of material changes through the Platform
• Provide reasonable notice before changes take effect

14.2 Your Continued Use

Your continued use of the Platform after changes to this Policy constitutes acceptance of the updated Policy. If you do not agree with the changes, you should discontinue use of the Platform.

14.3 Previous Versions

Previous versions of this Privacy Policy are available upon request. Contact us to request a copy of a previous version.

15. Contact Us

15.1 Privacy Inquiries

For privacy-related inquiries, questions, or to exercise your privacy rights, contact us at:

Email: x3na.io.notion@gmail.com
Subject line: Privacy Inquiry — [Brief Description]

15.2 Response Time

We aim to respond to privacy inquiries within 30 days (or as required by applicable law). For urgent matters, please indicate "URGENT" in your subject line.

15.3 Supervisory Authority

If you are located in the EEA and are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority. Our lead supervisory authority is the Estonian Data Protection Inspectorate.