This Privacy Policy outlines the data collection, use, and protection practices of the mobile app and web application "CoinFiesta" ("CoinFiesta" or "App") offered by Shanghai Liuhou Network Technology Co., Ltd.

LLC. Users may refer to § 11 for their contracting entity. By using CoinFiesta, you consent to the terms described herein. CoinFiesta reserves the right to change this Privacy Policy from time to time by changing it in the App.

§ 1 Legal Basis

For processing personal data, CoinFiesta may rely on one or more of the following legal bases:

-    CoinFiesta has received explicit consent to processing;

-    The processing is necessary in connection with a legal agreement;

-    The processing is required by law.

§ 2 Collection and Matter

Personal Info:

-    Email Address: Used for account management and re-engagement.

-    User IDs: Used for app functionality, analytics, personalization, account management.
Financial Info:

-    User Payment Info: Used for account management and payouts.

App Activity:

-    App Interactions: Used for app functionality, analytics, developer communications, personalization.

-    Installed Apps: Used for app functionality, advertising or marketing, personalization.

-    Usage data for Third-Party Apps: Used for app functionality, advertising or marketing, personalization.

App Info and Performance:

-    Crash Logs: Used for Analytics.

-    Diagnostics: Used for Analytics.

Device or Other IDs:

-    Device or Other IDs: Used for app functionality, analytics, developer communications, advertising or marketing, fraud prevention, security and compliance, personalization, account management.

Geo-location:

-    Used for location-based services, advertising or marketing, content delivery, fraud prevention, security and compliance.

§ 3 Cookies and Other Technologies

CoinFiesta may use cookies or similar technologies to collect information about your device, browser, and online behavior. These technologies help improve user experience, analyze site usage, and offer relevant content. Manage preferences through app settings.

§ 4 Data Sharing

All data sharing described in this Article is strictly limited to the minimum scope necessary and only for the specific purposes set forth below:

4.1 Recipients

(1) Affiliates: entities that control, are controlled by, or are under common control with CoinFiesta;

(2) Service Providers: third-party vendors engaged to perform account management, payment processing, technical support, security, risk management or other services;

(3) Law Enforcement and Regulators: only when required by applicable laws, judicial proceedings, or regulatory orders;

(4) Transaction Counterparties and Acquirers: only as necessary in the event of a corporate merger, acquisition, reorganization, or sale of assets.

4.2 Purposes of Sharing

— To fulfill contractual obligations or respond to user-initiated requests;

— To comply with legal, judicial, or regulatory requirements;

— To protect the security and integrity of the App, including fraud prevention and risk management;

— To conduct aggregated, anonymized analytics or research, ensuring no personally identifiable information is disclosed.

4.3 Security & Compliance Safeguards

(1) Enter into Data Processing Agreements or Non-Disclosure Agreements with all recipients, specifying permissible uses and security obligations;

(2) Perform compliance due diligence to verify recipients’ data-protection capabilities and certifications;

(3) Restrict access via role-based permissions and maintain detailed audit logs;

(4) In the event of any unauthorized disclosure or breach, notify affected users and authorities in accordance with applicable law and this Policy, and take prompt remedial action.

§ 5 Storage and International Transfers

User information is stored on secure servers. Transfers may occur to related parties, between the contracting entities and to third parties. Personal information may be transferred to China, Germany, the United States and other countries. By using CoinFiesta, you explicitly permit such transfers.

§ 6 Child Safety

CoinFiesta is intended for users aged 16 and above. We prioritize child safety online.

§ 7 External Links

Links to external sites may be present in CoinFiesta. CoinFiesta is not responsible for the privacy policies or content of these sites.

§ 8 Security

CoinFiesta employs security measures to protect personal information. While we make efforts to secure data, users should be aware that internet submissions are not entirely secure.

§ 9 Third Parties and Data Processors

Google Analytics: CoinFiesta uses functions of the analytics services Google Analytics and Google Firebase. Provider is Google Inc., 1600 Amphitheater Parkway Mountain View, CA 94043, USA. Google Analytics uses so-called "cookies". These are text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the United States and stored there. Firebase is used to attribute app installs to marketing campaigns and optimize the user experience in the app. For more information on how to handle user data, please see the Google Privacy Policy:
https://support.google.com/analytics/answer/6004245?hl=en

Meta: CoinFiesta uses functions of Meta. Provider is Meta Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. Meta is used to attribute app installs to marketing campaigns and optimize the user experience in the app. Meta Data Policy:
https://www.facebook.com/policy.php

§ 10 Contracting Entity and Jurisdiction

Your contracting entity is Shanghai Liuhou Network Technology Co., Ltd., Room J3554, Building 2, No. 4268 Zhennan Road, Jiading District, Shanghai. The governing laws are those of the China.

§ 11 Your Rights

Users have the right to access, correct, or delete personal information. For questions or concerns about this Privacy Policy or app usage, contact CoinFiesta’s Data Protection Officer via the feedback link in the app or write to [email protected].