1. Identity and Data Controller Information

Prime Players SL, based in Spain and owner of the Prime Players brand, is the controller of the personal data of users accessing its application and purchasing. The data processing is carried out in compliance with the General Data Protection Regulation (EU Regulation 2016/679) and other applicable data protection regulations.

2. Personal Data Processed

The personal data we may process includes:

• Identification data: name, surname, email address, phone number.
• Identity verification data (KYC): identification document (ID card, passport, or equivalent), proof of address.
• Financial data: bank account or payment card information.
• Data related to the purchase of tokens: number of tokens acquired, membership obtained, experiences requested, and other associated benefits.
• Data on app usage and navigation.

3. Purpose of Data Processing

Users’ personal data will be processed for the following purposes:

• Manage the registration and identity verification (KYC) process for users to purchase tokens, ensuring compliance with anti-money laundering and counter-terrorism financing regulations.
• Administer token purchase transactions and the allocation of memberships and experiences linked to the tokens.
• Send communications related to transactions and services provided.
• Offer discounts, merchandise, and VIP experiences, depending on the number of tokens purchased by the user.
• Conduct data analysis to improve services and user experience.
• Fulfill legal and tax obligations applicable to Prime Players SL.

4. Legal Basis for Processing

The legal basis for processing personal data includes:

• The execution of a contract, related to the purchase of tokens and associated services.
• Compliance with legal obligations, related to identity verification and other regulatory requirements.
• The user’s consent, for commercial communications or other processing activities not based on a legal or contractual obligation.

5. Data Retention

Personal data will be retained as long as the contractual relationship with the user remains active and afterward for the period required by applicable legal regulations, including tax, commercial, and anti-money laundering regulations.

6. Data Recipients

Prime Players SL will not share personal data with third parties, except in the following cases:

• When necessary for the provision of the service, such as payment or identity verification service providers.
• When there is a legal obligation.
• With the user’s consent.

7. User Rights

Users have the right to:

• Access their personal data.
• Request the correction of inaccurate data.
• Request the deletion of data when they are no longer necessary for the purposes they were collected.
• Object to the processing of their data.
• Request the restriction of data processing.
• Request the transfer of their data to another service provider (data portability).
• Withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise these rights, users can contact Prime Players SL via the email provided in the app.

8. Security Measures

Prime Players SL implements appropriate technical and organizational measures to ensure the security and confidentiality of personal data, protecting it against unauthorized access, loss, alteration, or disclosure.

9. Privacy Policy Modifications

Prime Players SL reserves the right to modify this privacy policy at any time. Changes will be notified to users through the app or by other appropriate means.

10. Contact

For any inquiries related to this privacy policy or to exercise user rights, users can contact Prime Players SL’s Data Protection Officer via email at: [email protected].