Privacy Policy

Bitsworld INC (“we,” “our,” and/or “us”) value the privacy of individuals who use our website, mobile applications (“Apps”), and related services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from users of our Services (“Users”) to improve the gaming experience. To protect our proprietary intellectual property, including the Core Concept—defined as Bitsworld's proprietary method of "putting history, timelines, events, and any information or elements from the universe (e.g., scientific data, cultural artifacts, or educational modules) onto the blockchain" through mechanics such as skill-verified timestamping, non-custodial NFT minting, fixed educational rewards, and immutable on-chain recording of achievements—we treat certain data (e.g., gameplay logs, quiz responses, on-chain timestamps, hashed mnemonics, derived addresses, vault representations, and cold wallet flow logs) as confidential trade secrets. Any misuse of such data to disclose, discuss, document, copy, derive, reverse-engineer, or commercialize our ideas, including CyberWall (our self-custodial multi-chain wallet for BTC, ETH, SHIB, DOGE with single-mnemonic derivation, Firebase-integrated vaults for asset reps like CyberCash, and secure cold wallet flows for air-gapped transfers/recovery), violates this Policy, our Terms of Service, and applicable trade secret laws (e.g., Defend Trade Secrets Act, 18 U.S.C. § 1836). Our Services include skill-based social gaming features like chess, poker, and our history-themed trading card game (TCG) using virtual in-game currency (e.g., Cybercoin and CyberToken), which may be redeemable for prizes via direct skill rewards. This is not real-money gambling where prohibited. No purchase is necessary to participate or earn rewards—free methods (e.g., learning quizzes, ad views) ensure equal access.

If you reside in California, Colorado, Connecticut, Oregon, Texas, Utah, or Virginia, please refer to our U.S. State Privacy Notice Addendum below for supplemental information about the types of personal information we collect and disclose, as well as how to exercise your rights under state law, including requests to confirm non-use of your data in IP infringement detection for the Core Concept or CyberWall.

For users of our Apps that are part of Apple Arcade, please refer to the “Apple Arcade” section below.

By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. You further agree to treat all aspects of the Core Concept (including mechanics, algorithms, designs, integrations, wallet setups, vault logic, and cold wallet protocols) as strictly confidential information and not to disclose, discuss, document, or share any details of the Core Concept with any third party, including via social media, forums, academic papers, or AI training datasets, without Bitsworld's prior written consent. This obligation survives termination of these Terms indefinitely. Violations may result in immediate account termination, forfeiture of all Virtual Items and rewards, and pursuit of all available legal remedies, including under the Defend Trade Secrets Act (18 U.S.C. § 1836) and equivalent international laws. Beyond this Privacy Policy, your use of our Services is subject to our Terms of Service, including the mandatory arbitration provisions in Section 16, which govern disputes related to your privacy and data. Users must be 21+ to access redeemable features; see Terms §2 for eligibility.

Information We Collect

We may collect a variety of information from or about you or your devices from various sources, as described below. If you do not provide your information as requested, you may not be able to use our Services if that information is necessary to provide our Services or we are legally required to collect it. Certain data tied to our proprietary concepts (e.g., historical quiz answers, TCG card claim patterns, on-chain timestamp logs, CyberWall-derived addresses, vault reps in Firebase, cold wallet connection logs) is collected solely to enforce fair play and protect IP, and is treated as confidential—disclosure or misuse may result in account termination and legal action.

Information You Provide Us

Registration and Profile Information

If you link our Services to a third party account, such as a Game Center, Google Play, or Facebook account, we may receive information about you from these third party services such as your email address, profile information, and friends list. If you wish to limit the information these third parties make available to us, we encourage you to visit the privacy settings for those third party accounts to learn about your options. Profile data linked to proprietary features (e.g., historical achievement badges or CyberWall wallet linkages) remains our IP and may not be exported for competitive use.

Payment Information

All purchases, including all in-app purchases, are handled by App store platforms such as Apple and Google. Outside of a payment receipt, which we receive for refund purposes and includes the date of purchase, the item purchased, and an anonymous identification number, we do not collect any payment information.

Communications

If you contact us directly, we may receive additional information about you. For example, if you contact our customer support team, we will receive your name, email address, device identifiers, phone manufacturer, operating system version (e.g., iOS or Android), the contents of the message and any attachments you may send to us, and any other information you choose to provide. If you subscribe to our newsletter, we will collect certain information from you such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services. Communications referencing our proprietary concepts (e.g., blockchain history mechanics or CyberWall recovery flows) are monitored to prevent IP leakage.

Careers

If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience. Any ideas submitted in applications become our property under our IP policies.

KYC/AML Information for Redemptions

For prize redemptions (e.g., converting Cybercoin to cryptocurrency like SHIB or DOGE via self-custodial wallets like CyberWall, or claiming TCG rewards), we collect limited Know Your Customer (KYC) data such as full name, date of birth, address, government ID (e.g., driver's license scan), and last 4 digits of SSN for users 21+ only. This ensures compliance with anti-money laundering (AML) laws and tax reporting (e.g., IRS Form 1099 for winnings over $600). We do not store full financial details or private keys. KYC data linked to proprietary reward mechanics (e.g., historical NFT claims or CyberWall vault withdrawals) is encrypted and access-restricted to prevent derivation of our IP, with hashed addresses stored in Firebase for recovery verification only.

Information We Collect When You Use Our Services

Location Information

When you use our Services, we infer your general location information based on technical information such as your internet protocol (IP) address, which may indicate your more general geographic region. We use this for geo-fencing restricted areas (e.g., states with restrictions on skill-based rewards like NY/MT).

Device Information

We automatically collect certain technical information about the device and software you use to access our Services, including your IP address, operating system version (e.g., iOS, Android), web browser type, phone manufacturer, device identifiers, media access control (MAC) address, and push notification tokens. For CyberWall, we collect temporary session data like derivation paths (e.g., m/44'/60'/0'/0/0 for ETH) and connection logs (e.g., Ledger WebHID), hashed for security—raw data never stored.

Your Contacts

If you give us permission to import your contacts from a third party account you link to our Services, such as your Game Center, Google Play, or Facebook account, we may access and store names and contact information from your address book to facilitate invitations and social interactions that you initiate through our Services and for other purposes described in this Privacy Policy or at the time of consent or collection. We also collect your contacts if you invite them to use our Services or share information or content with them from our Services. Imported contacts may not be used to solicit or share proprietary game data, including CyberWall addresses.

Messages Between Users

When you communicate with other Users on our Services through text chat, such as via the Messaging feature described in our Terms of Service, we and our third-party partners may receive the content of the messages you send and receive and information about those messages, such as when they were sent or received. Messages are scanned for potential IP risks (e.g., discussions of blockchain mechanics or CyberWall mnemonic backups) to safeguard trade secrets.

Game and Anti-Cheat Data

For fair play in skill games (e.g., chess/poker, history TCG), we log session data like moves, timestamps, card claims/unlocks, and device fingerprints to detect cheating (e.g., engine use) and verify reward eligibility (e.g., globe card positions). This data embodies our proprietary "history/time on the blockchain" algorithms and is a protected trade secret—any attempt to access or replicate it, including vault tx polls or cold wallet signatures, breaches these Terms.

Wallet and Vault Data

For CyberWall features, we collect hashed mnemonics (e.g., keccak256 for recovery verification), derived addresses (e.g., ETH/BTC/DOGE via BIP39 paths), vault reps (e.g., Firebase credits for deposited assets like 1 ETH rep upon tx confirmation), and cold wallet logs (e.g., connection timestamps, signed tx hashes)—never raw private keys or seeds. This enables non-custodial bridging; data is encrypted and access-logged. All such data is proprietary, treated as trade secrets, and monitored for misuse (e.g., unauthorized exports).

Information from Cookies and Other Tracking Technologies

We and third party partners collect information using cookies, pixel tags, SDKs, or other tracking technologies. Our third party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files that contain a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services. Please review your web browser “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete, or choose not to accept, cookies from our Services, you may not be able to utilize the features of the Service to their fullest potential. Tracking data related to proprietary features (e.g., TCG interactions or CyberWall vault polls) is anonymized but retained for IP enforcement.

Information We Receive from Third Parties

Other Third Parties

We may receive additional information about you, such as demographic data, from third parties such as data or marketing partners and combine it with other information we have about you. Third-party data is vetted to ensure no IP contamination, including no exposure to CyberWall-derived insights.

Blockchain Providers

For crypto redemptions, we receive anonymized transaction confirmations from partners (e.g., wallet providers like Infura for ETH polls) without storing private keys. Future on-chain features (e.g., NFT mints) will collect minimal data, processed non-custodially. On-chain data (e.g., historical event timestamps or CyberWall deposit txs) is public but our proprietary verification algorithms, vault liquidity logic, and cold flow integrations remain confidential.

How We Use the Information We Collect

We use the information we collect:

• To provide, maintain, improve, and enhance our Services;
• To personalize your experience on our Services such as by providing tailored content and recommendations;
• To understand and analyze how you use our Services and develop new products, services, features, and functionality;
• To communicate with you, provide you with updates and other information relating to our Services, provide you with information that you request, respond to comments and questions, and otherwise provide customer support;
• To facilitate the connection of third party services or applications, such as social networks and gaming apps;
• For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable, or otherwise of interest to you;
• To send you push notifications;
• To facilitate transactions and payments;
• To process your job application;
• To find and prevent fraud and abuse, and respond to trust and safety issues that may arise, including anti-cheat monitoring in games;
• For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency (e.g., IRS reporting for prizes over $600 annually);
• To verify eligibility and process KYC/AML for redemptions, ensuring only 21+ users in permitted jurisdictions receive prizes; and
• To process fixed reward claims in our history TCG, such as unlocking predetermined crypto (e.g., SHIB/DOGE) tied to specific globe cards via earned Cybercoin—no randomness involved;
• To monitor, detect, and enforce against IP infringements, such as unauthorized copying of proprietary mechanics (e.g., blockchain history integrations or CyberWall mnemonic hashing/vault syncing) via data patterns or shared content;
• To protect trade secrets, including analyzing session data for reverse-engineering attempts on cold wallet flows or vault algorithms; and
• For other purposes for which we provide specific notice at the time the information is collected.

How We Share the Information We Collect

Affiliates

We may share any information we receive with our affiliates for any of the purposes described in this Privacy Policy. Affiliates must sign NDAs to protect proprietary data, explicitly prohibiting derivation or use of "history/time on the blockchain" or CyberWall insights (e.g., vault liquidity patterns).

Vendors and Service Providers

We may share any information we receive with vendors and service providers retained in connection with the provision of our Services, including crypto wallet integrators (e.g., for CyberWall redemptions via Infura/Blockcypher), anti-cheat tools, and educational content partners for TCG card verification. All vendors are bound by strict NDAs prohibiting use or disclosure of data that could reveal or enable copying of our "history/time on the blockchain" concept or CyberWall (e.g., no analysis of derivation paths or vault polls for competitive purposes); audits ensure compliance. No vendor may aggregate or analyze shared data for competitive purposes.

User Content

Our Services are social services in which you can find, enjoy, and share content. If you choose to share content, like the games you’re playing or messages via the Messaging feature, with other Users, your username will be viewable by those Users. We are not responsible for the other users’ use of available information, so you should carefully consider whether and what to post or how you identify yourself on the Service. Shared content must not include or derive from proprietary mechanics, including CyberWall screenshots or vault balances; violations trigger IP claims under our Terms.

Third Party App Integrations

If you connect a third party application to our Services, we may share information such as your device identifier with that third party. Shared data excludes proprietary session logs, wallet hashes, or idea-derived insights like cold flow timestamps.

Social Networks and Other Online Services

The Service allows you to, upon your direction, share information with social networking services, such as X, Facebook, and Instagram. You understand and agree that the use of your information by any social networking websites will be governed by the privacy policies of these third party platforms and your settings on that platform. We encourage you to review their privacy policies before providing any information to them, especially for crypto wallets (e.g., risks of blockchain transactions). You agree not to share screenshots, descriptions, or data revealing our proprietary concepts, including CyberWall interfaces or vault tx confirmations, on such platforms.

Marketing

We may share information about you with third parties that is in an aggregate or de-identified form that cannot reasonably be used to identify you or reverse-engineer our IP, such as CyberWall usage aggregates without exposing algorithms.

Analytics Partners

We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information regarding your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. Analytics data is aggregated to prevent IP exposure, e.g., no granular vault or cold wallet metrics shared.

Advertising Partners

We work with third party advertising partners to show you ads that we think may interest you. These advertising partners may set and access their own cookies, pixel tags, and similar technologies on our Services and they may otherwise collect or have access to information about you which they may collect over time and across different online services. Some of our advertising partners are members of the Network Advertising Initiative ( http://optout.networkadvertising.org/?c=1#!/ ) or the Digital Advertising Alliance ( http://optout.aboutads.info/?c=2&lang=EN ). If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps. Ads do not disclose proprietary gameplay data, including CyberWall features.

Regulatory Bodies

We may share data with relevant authorities (e.g., IRS) for compliance, such as prize reporting, or law enforcement for AML/fraud investigations. Shares are limited to non-proprietary data; IP-related disclosures (e.g., suspected CyberWall misuse) require court order.

Blockchain and Educational Partners

Anonymized learning data shared with crypto providers for reward txns (e.g., DOGE sends via liquidity pools) and history fact-checkers for TCG quizzes. Partners execute NDAs to safeguard algorithm-derived insights, including vault bridging or cold signing protocols.

As Required By Law and Similar Disclosures

We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety , including enforcing IP rights against idea theft like CyberWall replication. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through our Services.

Merger, Sale, or Other Asset Transfers

We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected. Transfers include safeguards for proprietary data under NDA-equivalent agreements, ensuring CyberWall secrets remain protected.

Consent

We may also disclose your information with your permission. Consent does not extend to uses infringing our IP, such as sharing wallet derivation details.

Security

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain, including encryption for KYC data and multi-factor authentication for accounts. Proprietary data (e.g., blockchain algorithm logs, CyberWall hashed mnemonics, vault Firebase entries, cold wallet tx simulations) receives additional access controls, audits, zero-trust architecture, and Web Crypto API encryption to prevent reverse-engineering or leaks. However, because our Services are hosted electronically, and no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information. You assume the risk of any data breach or unauthorized access, and any disputes arising from such incidents are subject to arbitration as per Section 16 of our Terms of Service. In the event of a breach, we will notify affected users within 72 hours per best practices and applicable law and investigate for IP compromise, including forensic review of wallet/vault data.

Children

No part of our Services is directed to children under 13, and we do not knowingly collect, maintain, or use personal information from children under 13 years of age. For redeemable features (e.g., prizes, including TCG crypto rewards via CyberWall), users must be 21+. If you learn that a child under 13 (or under 21 for redemptions) has provided us with personal information in violation of this Privacy Policy, then you may alert us at support@bitsworld.io.

International Visitors

Our Services are hosted in the United States and intended for visitors located within the United States, with compliance focused on North Carolina laws. If you choose to use our Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law (e.g., GDPR, MiCA for crypto), please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Services. By providing any information, including personal information, on or to our Services, you consent to such transfer, storage, and processing. Non-US users must comply with local gambling/crypto laws; access may be restricted (e.g., no China). International transfers include IP safeguards compliant with Schrems II for EU data, with explicit NDA clauses for CyberWall-related shares.

Accessing/Updating Information

You can update your account and profile information through your profile settings. If you have any questions about your privacy on our Services or as described in this Privacy Policy, please contact us at support@bitsworld.io. Requests involving proprietary data (e.g., CyberWall address views) are subject to additional verification to prevent IP risks.

Deleting/Restricting Information

You can request the deletion of your personal information by submitting a request to support@bitsworld.io. You can ask us to restrict the processing of your personal information by submitting a request to support@bitsworld.io. If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time by submitting a request to support@bitsworld.io. Any disputes arising from such requests are subject to arbitration as per Section 16 of our Terms of Service. Note: We retain KYC data for 5 years per AML requirements and IP-related logs (e.g., anti-cheat data, CyberWall vault audits) for 7 years to support potential enforcement actions.

Information Retention

We retain your personal information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements) and for a period of time consistent with the original purpose as described in this Privacy Policy. We determine the appropriate retention period for personal information on the basis of the amount, nature, and sensitivity of your personal information processed, the potential risk of harm from unauthorized use or disclosure of your personal information, and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation). After expiration of the applicable retention periods, we will either delete or anonymize your personal information or, if this is not possible, then we will securely store your personal information and isolate it from any further processing until deletion is possible. General user data retained up to 2 years post-account closure unless legally required longer; KYC/AML data retained 5 years post-redemption ; proprietary data (e.g., blockchain mechanics logs, CyberWall hashed derivations, vault tx histories) retained indefinitely for IP defense or as trade secrets.

Trade Secret Safeguards

By accessing the Service, you certify under penalty of perjury that you understand the Core Concept is a non-public trade secret and agree to the following safeguards: (i) implement reasonable security measures to prevent unauthorized access to any notes or records of the Core Concept, including CyberWall mnemonics, vault exports, or cold wallet notes; (ii) notify Bitsworld immediately of any suspected disclosure or breach; and (iii) indemnify Bitsworld for any losses from your failure to maintain confidentiality. Bitsworld may require periodic attestations of compliance for high-value users (e.g., those redeeming large prizes via cold wallets). Any use, disclosure, or derivation of the Core Concept outside the limited license in Section 5.1 of the Terms of Service constitutes inequitable conduct. In the event of such breach, you agree to: (i) immediately assign to Bitsworld all rights, title, and interest in any derived works, patents, copyrights, or profits obtained therefrom; (ii) cooperate fully in Bitsworld's efforts to protect the Core Concept, including providing access to your devices, records, or code for forensic audit (at your expense); and (iii) pay liquidated damages of $50,000 per instance of misappropriation, in addition to actual damages, as a reasonable estimate of harm given the difficulty in quantifying loss to Bitsworld's competitive edge. This includes breaches involving CyberWall, such as unauthorized replication of multi-chain derivation, vault liquidity algorithms, or cold wallet recovery protocols. These remedies are cumulative and do not limit Bitsworld's right to seek injunctive relief or statutory damages under trade secret laws.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you via email or in-app notice. Continued use after changes means acceptance of enhanced IP protections for the Core Concept and CyberWall.