ChessPoint App Privacy Policy

Last Updated: November 24, 2025

Effective Date: November 24, 2025

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1. WHO WE ARE

This Privacy Policy explains how Emerging Nordic Ventures ("Chess Point," "Company," "We," or "Us"), a limited liability company registered in the Republic of Latvia (Reg. No. 40103655981), collects, uses, and shares your personal data when you use our website, Telegram Mini App, or services (collectively, the "Platform").For the purposes of the General Data Protection Regulation (EU) 2016/679 ("GDPR"), we are the Data Controller.Our Contact Details:• Entity: Emerging Nordic Ventures• Address: Rupniecibas str. 1-5, Riga, LV-1010, Latvia• Email for Privacy Requests: support@chesspoint.org

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2. DATA WE COLLECT

We collect data to provide the Platform, prevent cheating, and comply with legal obligations.

2.1. Information You Provide to Us

• Identity Data: Username, email address (if provided), or Telegram ID.• Wallet Data: Your public cryptocurrency wallet address (e.g., TON address) when you connect it to the Platform.• Communications: Records of your support tickets, emails, or disputes.

2.2. Automatically Collected Data

• Gameplay Data: All moves, timing, match results, and PGN (Portable Game Notation) files.• Device & Usage Data: IP address, browser type, device model, and operating system.• Anti-Cheat Telemetry: Behavioral data (mouse movement patterns, tab switching, reaction times) used to detect bot usage.

2.3. Blockchain Data (Public Ledger)

Important: Your wallet address and transaction history (deposits, prizes) are publicly recorded on the TON blockchain. We cannot control, delete, or hide this data, as the blockchain is an immutable public ledger.

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3. HOW AND WHY WE USE YOUR DATA

We only process your data when we have a lawful basis to do so.

PurposeData TypesLawful Basis (GDPR)To run the Service (Account creation, matchmaking, payouts)Identity, Wallet, GameplayPerformance of Contract (Art. 6.1.b)To prevent Cheating (Detecting engines/bots)Gameplay, Device, TelemetryLegitimate Interest (Art. 6.1.f) – Ensuring fair play integrity.To manage Payments & TaxesWallet, Transaction HistoryLegal Obligation (Art. 6.1.c) – Latvian accounting/AML laws.To improve the Platform (Analytics)Usage Data (Anonymized)Legitimate Interest (Art. 6.1.f)Marketing & NewslettersEmail AddressConsent (Art. 6.1.a) – You can opt-out anytime.

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4. DATA RETENTION

We will only retain your personal data for as long as necessary:• Account Data: Retained while your account is active. If you delete your account, we delete this data within 30 days, unless required by law.• Financial Records: We must keep records of payments/prizes for 5 to 10 years to comply with Latvian tax and Anti-Money Laundering (AML) laws.• Gameplay & Integrity Data: Chess games (PGNs) and cheat-detection logs are retained indefinitely to maintain the historical integrity of ratings and tournament results. This data is anonymized where possible.

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5. SHARING YOUR DATA

We do not sell your personal data. We may share it with:• Service Providers: Cloud hosting (e.g., AWS), payment processors, or email services acting as Data Processors.• Legal Authorities: If required by Latvian law, court order, or to report criminal activity (e.g., fraud/money laundering).• The Public: Your username, rating, and chess games are public profile information visible to other users.

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6. YOUR RIGHTS (GDPR)

Under the GDPR, you have the following rights:

  1. Right to Access: Ask for a copy of the data we hold about you.
  2. Right to Rectification: Correct inaccurate data (e.g., change your email).
  3. Right to Erasure ("Right to be Forgotten"): Ask us to delete your account.◦ Limitation: We cannot delete data stored on the blockchain. We also cannot delete game history that affects other players' ratings (integrity exception).
  4. Right to Restrict Processing: Pause data usage while a dispute is resolved.
  5. Right to Portability: Get your game history (PGNs) in a machine-readable format.To exercise these rights, email us at support@chesspoint.org. We generally respond within 30 days.

7. COOKIES AND TRACKING

We use cookies to keep you logged in and analyze site traffic.• Necessary Cookies: Required for the site to work (e.g., session tokens). You cannot switch these off.• Analytics Cookies: Help us understand visitor numbers. You can opt-out via your browser settings.

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8. INTERNATIONAL TRANSFERS

Your data may be processed on servers outside Latvia. If we transfer data outside the European Economic Area (EEA), we ensure protection through Standard Contractual Clauses (SCCs) approved by the European Commission.

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9. COMPLAINTS

If you believe we have violated your privacy rights, we encourage you to contact us first. If unsatisfied, you have the right to lodge a complaint with the Data State Inspectorate (Datu valsts inspekcija), the supervisory authority in Latvia.Data State Inspectorate (DVI)• Address: Elijas iela 17, Rīga, LV-1050, Latvia• Email: pasts@dvi.gov.lv• Website: www.dvi.gov.lv

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