Draft for review — Version 1.0
This Privacy Policy describes how BitBreakout LLC (“BitBreakout”, “we”, “our”, or “us”), a company incorporated in the State of Wyoming, United States, collects, uses, stores and otherwise processes your personal data when you use the BitBreakout website, mobile interfaces or any related service we provide (together, the “Service”).
Please read this Privacy Policy carefully together with our Terms of Service. By creating an account, entering a contest, or otherwise using the Service, you acknowledge that we process your personal data as described in this Privacy Policy.
If you do not agree with any part of this Privacy Policy, you should not use the Service.
The data controller responsible for your personal data is BitBreakout LLC, a Wyoming limited liability company with its principal office at 30 N Gould St Ste R, Sheridan, WY 82801, United States.
You can contact us about this Privacy Policy or any aspect of our processing of your personal data at privacy@bitbreakout.com.
For users located in the European Economic Area, the United Kingdom, Switzerland or Norway, we have appointed DataRep as our Article 27 representative (our “Data Representative”). You can contact our Data Representative at:
You can reach our Data Representative, or ask us to pass your request to them, by emailing privacy@bitbreakout.com.
This Privacy Policy applies to personal data we process in connection with the Service, including through:
It does not apply to websites, applications or services operated by third parties, even when accessed via a link from the Service. We encourage you to read the privacy notices of any third party whose service you use.
To create a BitBreakout account you must provide:
We do not ask for your date of birth or a numeric age at registration. At signup you must also tick two consent checkboxes: (i) acceptance of our Terms of Service and this Privacy Policy, and (ii) confirmation that you are eligible to use the Service (including being at least 18 years old, and not resident in any Restricted Jurisdiction) and accept ongoing responsibility for compliance. This eligibility confirmation is recorded as your attestation; we store the fact that you confirmed it, not an age value.
You can view and update your account details — your name, email address and country of residence — from your My Account page. Changing your email address requires you to verify the new address, and we will notify your previous address of the change. Because your name and country of residence can affect contest eligibility, sanctions screening and the verification of prize winners, we keep a record of changes to these details and may review significant changes manually; a change that cannot be reconciled with your verification documents may affect your eligibility to participate or to receive a prize.
From your My Account page you may choose to add optional profile information. This may include:
This information is entirely optional. It is not collected at registration, and it is not required to register, to apply for or take part in a contest, or to be eligible for a prize. We process it on the basis of your consent, which you give at the point you choose to provide it. You can add, change or remove any of these details at any time from your My Account page; removing a field withdraws your consent for that item. We keep a record of changes to these details so that we can evidence the consent you gave.
If you are among the winners of a contest, we will need to verify your identity before we can pay out any prize. In that case we will ask you to provide additional identity-verification information, which may include a copy of a government-issued photo identification, proof of residential address (such as a utility bill or bank statement dated within the last three months), and, where applicable, a tax-identification number. We will provide a full list of required documents to winners at the time of verification.
When you interact with the demo trading interface, we collect information about your activity, including:
When you use the Service, we and our infrastructure providers automatically collect technical information, including:
If you contact us (for example by email, through an in-app support function or by replying to a notification), we will collect the content of that communication, the email address or other identifier you use, and any metadata associated with it (such as the date, time and channel of the message).
We use personal data to operate and administer the Service, including to:
In addition to the operational purposes set out above, we process personal data, including trading-activity data, for research, analytics, commercial purposes and product-improvement. Specifically, we:
We rely on our legitimate interest in researching, improving and commercialising our products and services as the legal basis for this processing, subject to your right to object as described in section 11.
The term “pseudonymised” means that direct identifiers such as your name and email address are removed from the data set used for these purposes and replaced with an internal identifier. The data remains personal data under applicable law until it is fully anonymised.
Where data-protection law requires us to identify a legal basis for processing your personal data, we rely on one or more of the following:
We do not sell your personal data. We share personal data only in the circumstances described below, and only to the extent necessary for the relevant purpose:
BitBreakout LLC is established in the United States. Our infrastructure providers and affiliates may be located in the United States, the United Kingdom, the European Economic Area, the United Arab Emirates, Hong Kong, Japan, Singapore and other jurisdictions. As a result, your personal data may be transferred to, and stored and processed in, countries outside your country of residence, which may have different data-protection laws.
Where we transfer personal data out of the European Economic Area, the United Kingdom or Switzerland, we put in place appropriate safeguards such as the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, or another lawful mechanism. Copies of these safeguards are available on request from privacy@bitbreakout.com.
We may also transfer personal data, pseudonymised data and analytical outputs to our affiliates and successors located outside the United States for the purposes described in section 6.
We retain personal data only for as long as necessary for the purposes for which it was collected, including for the purposes of operating the Service, complying with our legal obligations, resolving disputes, defending legal claims and enforcing our agreements.
In practice this means:
Pseudonymised and aggregated data derived from trading activity may be retained indefinitely for the research, analytics and product-development purposes described in section 6.
Depending on where you are located, you may have the following rights in relation to your personal data, subject to applicable law:
To exercise any of these rights, please contact us at privacy@bitbreakout.com. We may need to verify your identity before responding to your request. We will respond to your request within the period required by applicable law, typically within one month.
We use a small number of strictly necessary cookies to operate the Service and keep you signed in securely. These are first-party cookies used to authenticate your session and protect against unauthorised access (for example, our auth_token and refresh_token cookies). They are set with the HttpOnly and SameSite attributes and, in production, are transmitted only over a secure HTTPS connection. Because these cookies are essential to providing the Service you have requested, they do not require your consent.
We do not currently use cookies for analytics, advertising, or behavioural tracking, and we do not set third-party cookies. You can delete or block cookies through your browser settings, but blocking our authentication cookies will prevent you from signing in to and using the Service. If we introduce analytics or other non-essential cookies in the future, we will update this notice and, where the law requires it, ask for your consent before those cookies are used.
The Service is intended for use only by persons aged 18 or over. We do not knowingly collect personal data from children under 18. If you believe that we have collected personal data from a child under 18, please contact us at privacy@bitbreakout.com and we will take appropriate steps to delete it.
We use a combination of technical and organisational measures to protect personal data against loss, misuse, unauthorised access, disclosure, alteration or destruction. These measures include encryption in transit, restricted access controls, logging and monitoring, hashing of passwords and regular security reviews.
No system can be guaranteed to be completely secure. You are responsible for keeping your account credentials confidential and for notifying us promptly of any suspected unauthorised access to your account.
We may update this Privacy Policy from time to time. When we do, we will update the “Effective date” at the top of this document and, where changes are material, we will notify you by email or through the Service before they take effect. Your continued use of the Service after a new version of this Privacy Policy takes effect constitutes your acknowledgement of the updated policy.
If you are located in the European Economic Area, the United Kingdom, Switzerland or Norway, the General Data Protection Regulation (or its national equivalent) applies to our processing of your personal data, and you have the rights set out in section 11. Our Data Representative for these regions can be contacted as described in section 2.
If you are located in the United Arab Emirates, the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) applies to our processing of your personal data. You have rights equivalent to those set out in section 11, and you can contact the UAE Data Office directly if you believe your rights have been infringed.
If you are located in Hong Kong, the Personal Data (Privacy) Ordinance applies to our processing of your personal data. You have rights of access and correction in respect of the personal data we hold about you, and you can contact the Office of the Privacy Commissioner for Personal Data if you believe your rights have been infringed.
All privacy questions and requests should be addressed to privacy@bitbreakout.com. Postal correspondence may be sent to our principal office at 30 N Gould St Ste R, Sheridan, WY 82801, United States.
Last updated: June 17, 2026