Privacy Policy

Effective date: November 10, 2026

This Privacy Policy explains how Bankroll ("Bankroll", "we", "us" or "our") handles information about people who visit the Bankroll website or use any Bankroll application, challenge, product or service (together, the "Services"). It covers what we collect, why we collect it, who we may share it with and the choices you have.

The Bankroll app is not live yet. Some parts of this policy describe processing that will only start once Accounts and Challenges become available.

By using the Services you confirm that you have read this policy. If you do not agree with it, please stop using the Services.

1. Scope

This policy applies to personal information that Bankroll processes in connection with the Services.

It does not apply to websites, apps or services run by third parties, even when the Services link to them. Those services have their own privacy policies, and we recommend reading them before you use them.

2. Who to contact

Bankroll is responsible for the processing described in this policy. Privacy questions and requests can be sent to our official X account, @TheBankrollGG, or through any other channel we announce on the website.

3. Information we collect

We may receive information directly from you, automatically when you use the Services, or from third parties where the law allows it. The lists below are examples, not a complete list.

3.1 Information you give us

When you create an Account, join a Challenge, ask for support or otherwise interact with us, you may provide:

• a username, email address and password
• your X or other social handle
• a cryptocurrency wallet address
• your country of residence and nationality
• billing details
• support requests, messages, survey answers, competition entries and feedback
• anything else you choose to send us

Please keep this information accurate and up to date.

3.2 Blockchain information

Some features interact with public blockchains. We may therefore process public on-chain data such as wallet addresses, transaction hashes and times, token transfers, smart contract interactions and visible balances. Blockchain records are public and generally permanent, and we cannot change or erase them.

3.3 Technical information

When you use the Services, we and our hosting providers may automatically record technical data, for example: IP address, browser and operating system, device type and identifiers, language settings, the page that referred you, pages viewed, time and length of visits, clicks, crash reports, diagnostic logs and an approximate location based on your IP address. We use this to run, secure and improve the Services.

3.4 Usage information

We may record how you use the Services, including Challenge participation, account and login activity, the features you use, completion rates, preferences, navigation and support history. This helps us fix problems, improve the product and prevent abuse.

3.5 Communications

If you contact us, we may keep the messages exchanged on X, in support tickets, by email where used, in disputes, in moderation and in feedback. We may review them for quality, fraud prevention and legal compliance.

3.6 Payment information

Where relevant, we may process limited payment data linked to crypto transactions: payment status, transaction identifiers, wallet addresses, times and the assets transferred.

We never collect, store or have access to your private keys, seed or recovery phrases or wallet passwords. Keeping your wallet safe is your responsibility.

3.7 Identity verification

We do not usually ask for identity checks, but we may do so when it is reasonably needed. In that case we, or a verification provider we choose, may process an ID document, proof of address, photos or a verification selfie and other documents reasonably needed to prevent fraud or meet legal duties. Verification providers may apply their own privacy policies.

4. Information we do not ask for

We do not intentionally collect sensitive categories of information, such as health, genetic or biometric data, racial or ethnic origin, political opinions, religious beliefs, trade union membership or information about sexual orientation. Please do not send it to us.

5. How we use information

We use personal information only for legitimate purposes connected with running the Services, for example to:

• create and manage Accounts
• give access to Challenges and process Challenge purchases
• run Funded Accounts and pay Profit Shares
• communicate with you and answer support requests
• investigate technical problems
• prevent fraud, abuse and prohibited conduct
• keep the Services secure and improve their performance
• build new products and features
• meet legal obligations, enforce our Terms and resolve disputes
• protect the rights, property and safety of Bankroll, our users and others

We do not make automated decisions with legal effects on you without appropriate human review.

6. Legal bases

Where the law requires a legal basis, we rely on one or more of the following:

• Contract: to create Accounts, run Challenges, provide Funded Accounts, pay Profit Shares and give support.
• Legitimate interests: to secure the Services, detect fraud and abuse, analyse and improve the platform, investigate suspicious activity, develop products and keep the business running. We weigh these interests against your privacy rights where required.
• Legal obligations: to comply with laws, court orders and requests from competent authorities, and to prevent financial crime.
• Consent: where we ask for it. You can withdraw consent at any time; this does not affect processing that took place before.

7. Sharing information

We do not sell personal information. We share it only when this is reasonably needed to run the Services or when the law requires it.

Recipients may include hosting and infrastructure providers, payment and blockchain infrastructure providers, support tools, analytics and security providers, professional advisers, auditors and insurers, as well as courts, regulators and law enforcement. Recipients may use the information only for the purposes we allow.

7.1 Business changes

If Bankroll is involved in a merger, acquisition, restructuring, financing, sale of assets or insolvency, personal information may be transferred as part of that transaction. We will take reasonable steps so that the recipient keeps protecting it in line with this policy or an equivalent one.

7.2 Legal disclosure

We may disclose information when reasonably needed to comply with the law, court proceedings or requests from public authorities, to protect our rights, to investigate fraud, to prevent illegal activity, to enforce agreements or to protect users and other people.

8. International transfers

We work internationally, so your information may be processed or stored outside your country, including in places with different data protection rules. Where the law requires it, we use appropriate safeguards for such transfers.

9. How long we keep information

We keep personal information only as long as reasonably needed to provide the Services, meet legal obligations, resolve disputes, prevent fraud, enforce our policies and establish or defend legal claims. The period depends on the type of information. Afterwards we delete it, anonymise it or combine it into statistics. Records on public blockchains are outside our control and cannot be deleted.

10. Security

We use reasonable technical and organisational measures to protect personal information, such as encryption, secure connections, restricted internal access, authentication controls, monitoring and security reviews. No system is completely secure, so we cannot guarantee absolute security. You are responsible for keeping your passwords and wallet credentials safe.

11. Your rights

Depending on the law that applies to you, you may have the right to:

• access your personal information
• correct inaccurate information
• ask us to delete it
• restrict or object to certain processing
• receive your information in a portable format
• withdraw consent where we rely on it

These rights are not absolute, and we may decline a request where the law allows or requires it. To use your rights, contact us on X at @TheBankrollGG. We may ask for additional information to confirm your identity before acting on a request.

12. Cookies

The Services may use cookies and similar technologies to keep you signed in, remember preferences, improve performance, analyse usage, prevent fraud and strengthen security. Cookies are small text files stored by your browser; some last only for a session and others stay longer. Third-party providers we work with may also set cookies under their own policies.

You can turn cookies off in your browser settings, but some features may then stop working properly.

13. Third-party services

The Services may connect to or link to third-party services, such as wallet providers, decentralized exchanges, blockchain infrastructure, hosting, analytics, support and communication tools, prediction market platforms and payment infrastructure. We do not control them and are not responsible for their privacy practices. Please read their policies before using them.

14. Children

The Services are not meant for anyone under 18, and we do not knowingly collect information from minors. If we learn that we have, we may delete the information and close the related Account. If you believe a minor has shared information with us, please tell us on X.

15. Marketing messages

We may sometimes send updates about the platform, new Challenges, maintenance, security and promotions. Where the law requires it, you can opt out of promotional messages. Service and security messages may still be sent.

16. Aggregated and anonymised data

We may create aggregated or anonymised data that no longer identifies anyone and use it for statistics, research, product development, platform optimisation and public reports. Such data is not personal information under this policy.

17. Changes to this policy

We may update this policy from time to time. If we make material changes, we will publish the new version on the website with a new effective date. Continuing to use the Services after that means you acknowledge the updated policy. Please check this page from time to time.

18. Final provisions

If any part of this policy is found unlawful, invalid or unenforceable, it will be applied to the maximum extent the law allows, and the rest will remain in effect. If we do not enforce any part of this policy, that is not a waiver of our rights. This policy is part of, and should be read together with, our Terms of Service and any other policies we publish.

By using the Services, you acknowledge that you have read and understood this Privacy Policy.