LEVR.bet Privacy Policy

1.Introduction

This Privacy Policy ("Policy") describes how LL HOSTING SERVICES SOCIEDAD DE RESPONSABILIDAD LIMITADA ("we", "our", or "us") collects, uses, stores, shares, and protects information in connection with the LEVR.bet front-end user interface (the "Interface" or "App") and the LEVR.bet smart contract infrastructure hosted on the Monad blockchain (the "Protocol").

This Policy should be read together with our Terms of Service (the "Terms"). Capitalized terms not defined in this Policy have the meanings given to them in the Terms.

By accessing or using the Interface and/or Protocol, or by creating an Account, you acknowledge that you have read, understood, and agree to be bound by this Policy. If you do not agree with this Policy, you must cease to access the Interface and use the Protocol immediately.

2.Information We Collect

2.1Information You Provide

When you create an Account or otherwise interact with the Interface, you may provide us with the following information:

• Account Information: username, email address, and public wallet address(es) you connect to the Interface.
• Communications: any information you provide when you contact us via our Discord server, the live chat on the Interface (powered by Crisp), or through other support channels, including the content of your messages and any attachments.
• Verification Information: if we request additional identity, residency, or source-of-funds verification under Section 3 of the Terms, the information you provide in response (for example, government-issued identification, proof of address, or similar documentation).
• Dispute and Claim Submissions: if you submit a dispute under Section 7.7 of the Terms or a request regarding a duplicate or erroneous transaction under Section 7.6, the information you provide in connection with that submission, including market identifiers, position details, and a description of the alleged error.

2.2Information Collected Automatically

When you access or use the Interface, we may automatically collect the following information:

• Device and Browser Information: device type, operating system, browser type and version, screen resolution, and language preferences.
• Network Information: Internet Protocol (IP) address, approximate geolocation derived from IP address, and internet service provider.
• Usage Information: pages viewed, features used, time and date of access, session duration, referral URLs, and clickstream data.
• Wallet and Transaction Information: public wallet address(es) connected to the Interface, on-chain transaction hashes, and interaction history with the Protocol as recorded on the Monad blockchain. We do not have access to your private keys.
• Promotion and Eligibility Information: records of your participation in campaigns and promotions, any promotional credits (as described in the Terms) issued to your Account or wallet address, and eligibility determinations we make for campaigns, promotions, and promotional credits based on your Interface activity and on-chain history.

2.3Information from Third Parties

We may receive information about you from third-party sources, including:

• Blockchain Analytics Providers: we use third-party blockchain analytics and sanctions-screening services (such as Chainalysis and TRM Labs) to screen wallet addresses against sanctions lists (including the OFAC SDN List), identify exposure to illicit activity, and assess compliance risk.
• Public Blockchain Data: transaction data, wallet balances, and smart-contract interactions that are publicly available on the Monad blockchain or other supported networks.

2.4Cookies and Similar Technologies

We may use cookies, local storage, and similar tracking technologies to operate the Interface, remember your preferences, and improve your experience. Some of these technologies may be provided by third-party analytics or performance providers.

• Strictly Necessary Cookies: required for the Interface to function (for example, session management, authentication state, and security tokens). These cannot be disabled.
• Analytics and Performance Cookies: used to understand how users interact with the Interface, measure performance, and improve functionality. We use Google Analytics for usage analytics and Addressable for wallet-based attribution and retargeting. These services may set their own cookies or tracking technologies on your device.

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Interface.

3.How We Use Your Information

We use the information we collect for the following purposes:

• Providing the Interface and Protocol Access: to operate, maintain, and provide you with access to the Interface and the features available through your Account, including campaigns, promotions, promotional credits, vault rushes, airdrops, testnets, leaderboards, market settlement, and position liquidation monitoring.
• Promotions and Promotional Credits: to determine your eligibility for campaigns and promotions; to compile lists of Accounts and wallet addresses eligible to receive promotional credits or other promotional benefits; to issue, administer, restore, expire, and revoke promotional credits in accordance with the Terms and any applicable Campaign Terms; and to detect and prevent abuse of promotional mechanics, including multi-accounting, Sybil activity, collusion, and automated participation.
• Account Administration: to create, maintain, suspend, restrict, or close your Account in accordance with the Terms.
• Compliance, Sanctions Screening, and Fraud Prevention: to screen wallet addresses and Account information against sanctions lists (including OFAC SDN, UN, EU, and HMRC lists); to detect, prevent, and investigate fraud, multi-accounting, Sybil activity, and other prohibited conduct; to comply with applicable laws and regulations, including anti-money-laundering (AML) and counter-terrorism-financing (CTF) requirements; and to respond to valid requests from law-enforcement, sanctions, tax, or regulatory authorities.
• Eligibility Verification: to verify that you meet the eligibility requirements in Section 2 of the Terms, including geolocation verification and Restricted-Person screening.
• Communications: to respond to your inquiries, provide customer support, and send you notices related to your Account or material changes to the Terms or this Policy.
• Security: to protect the Interface, Protocol, our systems, and our users from unauthorized access, cyberattacks, and other security threats.
• Improvement, Analytics, and Marketing: to analyze usage patterns, measure performance, identify bugs or errors, and improve the Interface and our products and services; and to conduct wallet-based attribution and retargeting through Addressable, which tracks wallet signups and enables us to deliver targeted communications to users who have interacted with the Interface.
• Legal Obligations and Dispute Resolution: to comply with applicable legal obligations, enforce our Terms, and resolve disputes, including reviewing market settlement disputes submitted under Section 7.7 of the Terms and assessing requests related to erroneous or duplicate transactions under Sections 7.4 and 7.6 of the Terms.

4.Legal Bases for Processing

Where applicable data protection law requires a legal basis for processing, we rely on the following:

• Contractual Necessity: processing necessary to perform our obligations under the Terms, including providing the Interface, administering your Account, and processing transactions.
• Legitimate Interests: processing necessary for our legitimate interests, including fraud prevention, security, compliance, and improving our products and services, where those interests are not overridden by your data protection rights.
• Legal Obligation: processing necessary to comply with applicable laws, regulations, court orders, or binding requests from regulatory or law-enforcement authorities, including sanctions and AML/CTF obligations.
• Consent: where we rely on your consent (for example, for certain analytics cookies or marketing communications), you have the right to withdraw consent at any time by contacting us via our Discord server or the live chat on the Interface. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

5.How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

• Service Providers: with third-party service providers who perform services on our behalf. These currently include: cloud hosting and infrastructure providers; blockchain analytics and sanctions-screening providers; SendGrid (transactional email); Crisp (live chat and customer support); Google Analytics (usage analytics); and Addressable (wallet-based attribution and retargeting). These providers are contractually obligated to use your information only for the purposes for which it is disclosed and to maintain appropriate security measures.
• Compliance and Legal Process: with law-enforcement, sanctions, tax, or regulatory authorities, including OFAC, when we are required or permitted to do so by applicable law, regulation, court order, subpoena, or valid government request; or when we determine in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, or to detect, prevent, or address fraud, security, or technical issues.
• Blocked Property and Sanctions Reporting: where we are required to block, hold, or report property under applicable sanctions or AML law, we may disclose Account information, wallet addresses, IP addresses, transaction data, and related information to the relevant authorities as required by law.
• Corporate Transactions: in connection with a merger, acquisition, reorganization, sale of assets, or similar corporate transaction, your information may be transferred to the acquiring or surviving entity, provided the recipient agrees to process your information in a manner consistent with this Policy.
• With Your Consent: in any other circumstances where you have given your express consent to the disclosure.

6.Data Retention

We retain your information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting obligations. Specific retention periods depend on the nature of the information and the purpose of processing:

• Account Information: retained for the duration of your Account and for a period of five (5) years after Account closure, or longer where required by applicable law or regulation (for example, AML record-keeping requirements).
• Compliance and Sanctions Records: retained for at least five (5) years from the date of the relevant screening, action, or transaction, or longer where required by applicable sanctions, AML, or CTF law.
• Server Logs and IP Data: retained for twelve (12) months from the date of collection, unless a longer retention period is required for an active investigation, legal proceeding, or regulatory obligation.
• Communications: retained for three (3) years from the date of the communication, or longer where relevant to an ongoing dispute, investigation, or legal obligation.

When retention is no longer required, we will securely delete or anonymize your information in accordance with applicable law.

7.Data Security

We implement commercially reasonable administrative, technical, and physical safeguards to protect your information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit and at rest, access controls, and regular security assessments.

However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your information, we cannot guarantee its absolute security. You are solely responsible for maintaining the confidentiality of your Account credentials, private keys, and wallet access.

8.International Data Transfers

We are incorporated in Costa Rica, and your information may be processed and stored in the United States or other jurisdictions where our service providers operate. These jurisdictions may have data-protection laws that differ from those in your jurisdiction.

Where we transfer your information to a jurisdiction that does not provide an equivalent level of data protection, we will implement appropriate safeguards (such as standard contractual clauses or other mechanisms recognized under applicable law) to ensure that your information is protected in accordance with this Policy.

9.Your Rights

Depending on your jurisdiction, you may have the following rights with respect to your personal information:

• Access: the right to request confirmation of whether we process your personal information and, if so, to request a copy of that information.
• Correction: the right to request that we correct inaccurate or incomplete personal information.
• Deletion: the right to request that we delete your personal information, subject to certain exceptions (for example, where retention is required for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims).
• Restriction: the right to request that we restrict the processing of your personal information in certain circumstances.
• Portability: the right to request that we provide your personal information in a structured, commonly used, and machine-readable format.
• Objection: the right to object to processing based on our legitimate interests.
• Withdrawal of Consent: where processing is based on consent, the right to withdraw consent at any time.

To exercise any of these rights, please contact us via our Discord server or the live chat on the Interface. We will respond to your request within a reasonable timeframe and in accordance with applicable law. We may ask you to verify your identity before processing your request.

Please note that certain rights may be limited where we have an overriding legitimate interest or a legal obligation to retain or process your information (for example, sanctions or AML record-keeping obligations). Where a right is limited, we will explain the reason.

10.Children's Privacy

The Interface and Protocol are not directed to, and are not intended for use by, persons under the age of eighteen (18) or the age of majority in their jurisdiction, whichever is higher. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a person under the applicable age threshold, we will take steps to delete that information promptly. If you believe that a child has provided us with personal information, please contact us via our Discord server or the live chat on the Interface.

11.Third-Party Links and Services

The Interface may contain links to third-party websites, applications, or services that are not owned or controlled by us. This Policy does not apply to any third-party services. We are not responsible for the privacy practices of any third party. We encourage you to review the privacy policies of any third-party services you access through or in connection with the Interface.

12.Blockchain Transactions and Public Data

Please be aware that transactions conducted through the Protocol are recorded on the Monad blockchain (or other supported public blockchains) and are publicly visible. This includes wallet addresses, transaction amounts, and smart-contract interactions. Once data is recorded on a public blockchain, it cannot be modified or deleted by us or by any single party. This Policy does not apply to information that is publicly available on a blockchain network, as such information is outside our control.

13.Do Not Track Signals

Some browsers transmit "Do Not Track" (DNT) signals. At this time, we do not respond to DNT signals. We will update this Policy if our practices change in the future.

14.Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. Where you have an Account, we will use commercially reasonable efforts to notify you of material changes by email to the address associated with your Account and by posting a notice within the Interface prior to the effective date of such changes. Your continued access to or use of the Interface or any Account after the effective date constitutes acceptance of the updated Policy.

We encourage you to review this Policy periodically. The "Last Updated" date at the top of this Policy indicates when it was most recently revised.

15.Contact Us

If you have any questions, concerns, or requests regarding this Policy or our data practices, please contact us at:

LL Hosting Services Sociedad de Responsabilidad Limitada
Discord: Join our Discord for support inquiries
Live Chat: available on the Interface (powered by Crisp)

16.Supplemental Notice for Costa Rica Residents

If you are a resident of Costa Rica, you may have additional rights under Costa Rica's Law on the Protection of Persons Against the Processing of Their Personal Data (Law No. 8968) and its implementing regulations, including the right to access, correct, and delete your personal information held by us. To exercise these rights, please contact us via our Discord server or the live chat on the Interface. We will process your request in accordance with applicable Costa Rican law.

17.Supplemental Notice for EU/EEA Residents

Although the Interface is not offered to residents of the European Union or European Economic Area (as set forth in our Terms of Service), if EU/EEA data protection law (including the General Data Protection Regulation, Regulation (EU) 2016/679) applies to our processing of your personal information for any reason, you may have additional rights under that law, including the rights described in Section 9 above. Our legal bases for processing are described in Section 4. For transfers outside the EU/EEA, we implement appropriate safeguards as described in Section 8. You may also have the right to lodge a complaint with a supervisory authority in your member state.