Privacy Policy

Last updated: April 2026

Owner and Data Controller

ponzi

Owner contact email: privacy@ponzi.game

Types of Data Collected

The Owner does not provide a list of Personal Data types collected. Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using this Application. Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services.

This Application may use Cookies or other tracking tools to provide the services required by the User. Users are responsible for any third-party Personal Data obtained, published, or shared through this Application.

Mode and Place of Processing the Data

Methods of Processing — The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.

In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, hosting providers, IT companies) appointed, if necessary, as Data Processors by the Owner.

Place — The Data is processed at the Owner's operating offices and in any other places where the parties involved with the processing are located. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own.

Retention Time — Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users' consent.

Blockchain Data

ponzi is a decentralised application built on the Base network (Ethereum L2). By interacting with the smart contracts, Users acknowledge that blockchain transactions are inherently public and immutable. Wallet addresses, transaction amounts, and interaction data are recorded on-chain and cannot be modified or deleted.

The Owner does not control the Base network or any blockchain infrastructure and cannot alter or remove on-chain data. This data is not considered Personal Data under most jurisdictions unless it can be linked to an identified individual.

Information for Users in the European Union

This section applies to all Users in the European Union, under the General Data Protection Regulation (GDPR), and for such Users, supersedes any other possibly divergent or conflicting information contained in this privacy policy.

Legal Basis of Processing — The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes.
  • Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof.
  • Processing is necessary for compliance with a legal obligation to which the Owner is subject.
  • Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

Rights of Users — Users may exercise certain rights regarding their Data processed by the Owner, including the right to:

  • Withdraw their consent at any time.
  • Object to processing of their Data.
  • Access their Data.
  • Verify and seek rectification.
  • Restrict the processing of their Data.
  • Have their Personal Data deleted or otherwise removed.
  • Receive their Data and have it transferred to another controller.
  • Lodge a complaint before their competent data protection authority.

Additional Information

Legal Action — The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.

System Logs and Maintenance — For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (system logs) or use other Personal Data (such as the IP Address) for this purpose.

Changes to This Privacy Policy — The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page. Users are encouraged to check this page frequently.

Definitions

  • Personal Data (or Data): Any information that directly, indirectly, or in connection with other information allows for the identification or identifiability of a natural person.
  • Usage Data: Information collected automatically through this Application, including IP addresses, URI addresses, time of request, method utilized, and other parameters related to the User's browser and operating system.
  • User: The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
  • Data Controller (or Owner): The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
  • This Application: The means by which the Personal Data of the User is collected and processed.