BitBreakout Contest

1. Introduction

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.

2. Who we are and how to contact us

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.

3. Scope of this Privacy Policy

This Privacy Policy applies to personal data we process in connection with the Service, including through:

account registration and authentication;
participation in a trading contest or any selection process for a contest;
use of the demo trading interface (including order entry, chart viewing, and related features);
communications with us, including email, support channels and feedback forms; and
use of our websites, including technical and device information collected automatically.

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.

4. Personal data we collect

4.1 Data you provide when you register for an account

To create a BitBreakout account you must provide:

your first name and last name;
your email address;
a password (which we store only in hashed form);
your country of residence.

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.

4.2 Data you provide when you apply for, or are selected into, a contest

When you apply to participate in a specific contest, we may ask you to provide additional information for the purposes of eligibility screening, contest administration and the integrity of the contest. This may include:

your gender;
your employment status;
your highest level of education completed;
your annual income range; and
your previous trading experience.

Except where stated otherwise in the applicable contest rules, these fields are optional at account creation and are collected only when you apply to a contest. You may choose not to answer any optional question; however, some answers may be required for you to be considered eligible for a particular contest.

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.

4.3 Data we collect as you use the Service

When you interact with the demo trading interface, we collect information about your activity, including:

orders placed, modified or cancelled (including the instrument, side, size, order type, price, leverage and timestamps);
order fills, position states, unrealised and realised profit or loss;
margin and balance changes to your contest wallet;
interactions with the charting and market-data interface; and
in-app notifications, alerts and configuration preferences.

4.4 Technical and device data

When you use the Service, we and our infrastructure providers automatically collect technical information, including:

your IP address and approximate location derived from it;
information about the browser, operating system, device type and screen resolution;
session and authentication tokens;
pages visited, actions taken and timestamps; and
diagnostic, performance and error logs.

4.5 Communications data

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).

5. How we use your personal data

We use personal data to operate and administer the Service, including to:

create and authenticate your account;
administer contests, including applying eligibility criteria, selecting participants, operating the demo trading interface, determining contest standings and paying out prizes;
verify the identity of prize winners and comply with tax-reporting and anti-fraud obligations in connection with prize payments;
detect, investigate and prevent fraud, abuse of the Service, manipulation of contest outcomes, multi-accounting and violations of our Terms of Service;
communicate with you about the Service, including account, security and contest-related notices;
send you marketing communications, where you have consented to receive them and subject to your ability to withdraw consent at any time;
respond to your enquiries and support requests;
monitor, debug, maintain and improve the Service;
comply with legal, regulatory, accounting and audit obligations to which we are subject; and
establish, exercise or defend legal claims, including in connection with disputes with users, service providers or third parties.

6. Research, analytics and product development

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:

analyse pseudonymised and aggregated trading activity from the Service to study user behaviour, improve contest formats and support product development;
derive statistics, signals, aggregated metrics and other analytical outputs from that activity;
use such analytical outputs to develop, test and offer data-based products and services; and
transfer such pseudonymised and aggregated data, and such analytical outputs, to our affiliates, successors and service providers for the purposes set out above, including for the development and provision of data-based products and services by those affiliates or successors.

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.

7. Legal bases on which we rely

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:

Performance of a contract — to provide the Service, administer your account and run any contest you enter.
Legitimate interests — for fraud prevention, security, product improvement, research and analytics as described in section 6, and for the administration of our business.
Consent — for certain marketing communications, the use of non-essential cookies, and any other purpose for which we expressly request consent. You may withdraw your consent at any time.
Compliance with a legal obligation — for example tax reporting, responding to valid requests from public authorities, and maintaining records we are legally required to keep.
Establishment, exercise or defence of legal claims — where this is necessary to protect our legal rights or those of third parties.

8. How we share your personal data

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:

Service providers — we use third-party providers for hosting, cloud infrastructure, email delivery, analytics, and customer support, and, where applicable, for prize fulfilment, identity verification and sanctions screening. Winner identity verification, sanctions screening and the transfer of prize funds may be performed by us or by a third-party provider engaged by us. Any such provider acts on our instructions and is contractually bound to protect your data.
Identity verification and sanctions screening — if you win a prize, identity verification and sanctions screening will be carried out, before paying out, by us or by a third-party provider we engage. Where a third-party provider holds your documents, BitBreakout receives only a verification result (pass / fail / sanctions concern) and the data fields needed to operate the contest, not full document copies.
Affiliates and successors — we may share personal data, pseudonymised data and analytical outputs with any current or future affiliate of BitBreakout LLC and with any successor entity arising out of a reorganisation, merger, acquisition or sale of all or part of our business, for the purposes set out in this Privacy Policy.
Professional advisers — we may share data with our lawyers, accountants, auditors and insurers where necessary for the administration of our business or the defence of legal claims.
Law-enforcement and regulatory authorities — we will disclose personal data where we are legally required to do so, including in response to a valid court order, subpoena, regulatory request or similar legal process, and where we reasonably believe disclosure is necessary to protect the rights, property or safety of BitBreakout, our users or the public.
With your consent — in any other case, we will share your data only where you have given us your consent to do so.

9. International transfers

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.

10. Data retention

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:

Account data is retained for as long as your account is active, and for a reasonable period afterwards to allow for account reactivation, dispute resolution and fraud prevention.
Contest application and participation data, including trading activity, is retained for up to seven years from the end of the relevant contest, to meet tax, accounting and audit requirements and to support research and product development.
Identity-verification data collected from prize winners is retained for as long as required by applicable anti-money-laundering and tax-reporting laws.
Marketing-consent records are retained until you withdraw consent and thereafter only to the extent necessary to evidence that the consent was given.
Technical logs are typically retained for up to 12 months, subject to longer retention where required for security investigations.

Pseudonymised and aggregated data derived from trading activity may be retained indefinitely for the research, analytics and product-development purposes described in section 6.

11. Your rights

Depending on where you are located, you may have the following rights in relation to your personal data, subject to applicable law:

the right to access the personal data we hold about you and to obtain a copy of it;
the right to request that we correct inaccurate or incomplete personal data;
the right to request that we erase personal data we hold about you, subject to legal exceptions;
the right to request that we restrict our processing of your personal data in certain circumstances;
the right to object to our processing of your personal data, including processing based on our legitimate interests and processing for direct marketing;
the right to data portability, meaning the right to receive your personal data in a structured, commonly used and machine-readable format, and to transmit it to another controller;
the right to withdraw consent at any time where we rely on consent as the basis for processing; and
the right to lodge a complaint with a data-protection authority in your country of residence, place of work, or the place where the alleged infringement occurred.

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.

12. Cookies and similar technologies

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.

13. Children

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.

14. Data security

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.

15. Changes to this Privacy Policy

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.

16. Jurisdiction-specific information

16.1 European Economic Area, United Kingdom, Switzerland and Norway

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.

16.2 United Arab Emirates

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.

16.3 Hong Kong

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.

17. Contact

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.