1. Introduction

Drawby is operated by Tidalwave Dynamics Limited ("the Company"), registered in Cyprus under Company Number HE 484196, with its Registered Office at Agiou Andreou 3, Pallouriotissa, 1040, Nicosia, Cyprus. The Company is the data controller. References in this Privacy Policy to "we", "our", or "us" mean the Company. We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform.

2. Information We Collect

2.1 Information You Provide

• Wallet Address: Your cryptocurrency wallet address when you connect to the Platform
• Contact Information: Email address if you subscribe to notifications
• Shipping Information: Name, address, and phone number if you win a physical prize
• Communications: Any information you provide when contacting support

2.2 Information Collected Automatically

• Transaction Data: Details of your ticket purchases and participation history
• Device Information: Browser type, operating system, and device identifiers
• Usage Data: Pages visited, time spent, and interaction patterns
• IP Address: For security, fraud prevention, and geographic restrictions

2.3 Blockchain Data

Please note that blockchain transactions are public by nature. Your wallet address and transaction history on the blockchain are visible to anyone.

3. How We Use Your Information

We use collected information to:

• Process your raffle entries and ticket purchases
• Deliver prizes to winners
• Communicate important updates about competitions
• Prevent fraud and ensure platform security
• Comply with legal obligations and enforce our terms
• Improve our services and user experience
• Send marketing communications (with your consent)

4. Legal Basis for Processing

We process your personal data based on:

• Contract Performance: To fulfill our obligations when you participate in raffles
• Legitimate Interests: For fraud prevention, security, and service improvement
• Legal Compliance: To meet regulatory and legal requirements
• Consent: For marketing communications and optional features

5. Information Sharing

We share your information with the service providers listed below, with legal authorities when required by law or to protect our rights, and in connection with a merger, acquisition, or sale of assets.

We do not sell your personal information to third parties for marketing purposes.

5.1 Service Providers

6. Data Retention

We retain your information for:

• Account Data: As long as your account is active plus 2 years
• Transaction Records: 7 years for legal and tax compliance
• Marketing Preferences: Until you withdraw consent
• Support Communications: 3 years from resolution

7. Your Rights

Depending on your location, you may have the right to:

• Access the personal data we hold about you
• Correct inaccurate or incomplete data
• Request deletion of your data ("right to be forgotten")
• Restrict or object to processing
• Data portability
• Withdraw consent at any time

To exercise these rights, contact us at privacy@drawby.com.

8. Cookies and Tracking

We use the following cookies and similar technologies:

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect platform functionality.

9. Security

We implement industry-standard security measures to protect your data, including encryption of data in transit and at rest, access controls, and monitoring for suspicious activity. Our smart contracts are audited by [auditor name]. Web infrastructure penetration testing is scheduled for [date].

However, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security of your data.

10. International Transfers

Your information may be transferred to and processed in countries outside your residence. We ensure appropriate safeguards are in place, including Standard Contractual Clauses or equivalent mechanisms approved by relevant authorities.

11. Children's Privacy

Drawby is not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors. If we learn we have collected data from a minor, we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes via email or platform notification. The "Last updated" date indicates when the policy was last revised.

13. Contact Us

For privacy-related inquiries:

• Email: privacy@drawby.com
• Data Protection Officer: dpo@drawby.com