Privacy Policy

1. Who We Are

Unipoly Chain Ltd. ("Unipoly," "we," "us," "our") operates the Unipoly Chain blockchain and its associated ecosystem of products and services accessible at unpchain.com, unitribe.app, and related domains. This Privacy Policy applies to all users of the Unipoly Chain ecosystem, including:

• Unipoly Chain — Our Layer 1 blockchain platform and chain explorer
• UNP Coin — Our native cryptocurrency and governance token
• UniTribe — Decentralized social media platform
• UniTube — Video sharing and streaming platform
• Kuki Games — Play-to-earn gaming platform
• UniHunt — Location-based augmented reality gaming
• Creator Studio (UCE) — Content creation tools and NFT marketplace
• Gabby Birds — Mobile gaming experience
• Digital Banking — Crypto and fiat financial services
• OCAP — On-Chain Agreement Protocol for smart legal contracts
• Unipoly Wallet — Blockchain wallet and key management
• DEX — Decentralized exchange for token trading

Our company is registered in Dubai, United Arab Emirates. For any privacy queries, contact us at privacy@unpchain.com.

2. Information We Collect

We collect personal data through the following means:

a) Information You Provide Directly:

• Account Registration: Email address, username, password (hashed), and optional profile information.
• KYC Verification: For banking and regulated services — government-issued ID, proof of address, date of birth, and selfie verification.
• Social Features: Profile photos, bios, posts, comments, and messages on UniTribe and UniTube.
• OCAP Agreements: Names, digital signatures, evidence files, and agreement terms submitted to OCAP smart contracts.
• Support Requests: Information you share in support tickets or live chat.

b) Information Collected Automatically:

• Device & Technical Data: IP address, browser type and version, operating system, screen resolution, device identifiers, and language preferences.
• Usage Data: Pages visited, features used, clickstreams, session duration, referring URLs, and in-app actions.
• Location Data: Approximate location from IP address; precise location only for UniHunt (GPS, with explicit consent).
• Cookie & Tracking Data: Cookies, local storage, web beacons, and pixel tags (see Section 8).

c) Blockchain Data:

• Wallet Addresses: Public blockchain wallet addresses associated with your account.
• Transaction Data: All on-chain transactions are publicly recorded on the Unipoly blockchain and cannot be deleted.
• Smart Contract Interactions: Records of your interactions with smart contracts, including OCAP agreements, DEX trades, and staking operations.

3. How We Use Your Information

We process your personal data for the following purposes:

• Service Delivery: Creating and managing accounts, processing transactions, executing OCAP smart contracts, enabling wallet functionality, and providing customer support.
• Platform Operations: Moderating content on UniTribe and UniTube, facilitating gameplay on Kuki Games, UniHunt, and Gabby Birds, and operating the DEX and banking services.
• Security & Fraud Prevention: Detecting unauthorized access, preventing fraud, monitoring for malicious activity, and enforcing our Terms of Service.
• Regulatory Compliance: Fulfilling AML/KYC obligations, responding to legal requests, and complying with applicable laws in the UAE and internationally.
• Analytics & Improvement: Understanding usage patterns, improving platform performance, developing new features, and conducting A/B testing (using anonymized data).
• Communication: Sending transaction confirmations, security alerts, service updates, and (with consent) promotional content.
• Personalization: Customizing content feeds on UniTribe and UniTube, recommending games on Kuki, and tailoring the user experience based on preferences.

4. Legal Basis for Processing

We process your data based on the following legal grounds:

• Consent: For marketing communications, analytics cookies, location data in UniHunt, and optional data collection.
• Contractual Necessity: For providing our services, managing your account, processing transactions, and executing OCAP agreements.
• Legal Obligation: For KYC/AML compliance, tax reporting requirements, and response to legal orders.
• Legitimate Interest: For platform security, fraud detection, service improvement, and internal analytics.

For more details on our legal basis under GDPR, see our dedicated GDPR Compliance page.

5. How We Share Your Data

We never sell your personal data. We may share information in the following limited circumstances:

• Service Providers: Trusted third-party processors who assist with hosting, analytics, KYC verification, payment processing, and email delivery — all bound by Data Processing Agreements.
• Legal Requirements: When required by law, regulation, or legal process, or to protect the rights, property, or safety of Unipoly, our users, or the public.
• OCAP Arbitration: When an OCAP agreement enters arbitration, relevant agreement data may be shared with the Unipoly Legal Team and appointed arbitrators.
• Blockchain Public Data: Wallet addresses and transaction data are inherently public on the blockchain.
• Business Transfers: In the event of a merger, acquisition, or sale, your data may be transferred to the successor entity with equivalent privacy protections.

6. International Data Transfers

Unipoly Chain operates globally. Your data may be processed in:

• United Arab Emirates — Our primary operational base.
• European Economic Area — For users accessing EEA-based services.
• Cloud infrastructure regions — Where our hosting providers maintain data centers.

When we transfer data outside the EEA, we implement appropriate safeguards including EU Standard Contractual Clauses (SCCs), Data Processing Agreements, and encryption in transit and at rest.

7. Data Retention

We retain your personal data only as long as necessary:

• Active Account Data: Retained while your account is active and for 12 months after account closure.
• Transaction Records: 5 years (financial regulatory requirement).
• KYC/AML Data: 5—7 years after account closure (regulatory requirement).
• Analytics Data: Anonymized after 26 months.
• Marketing Consent Records: Retained for the duration of consent plus 12 months.
• Support Tickets: 24 months after resolution.
• Blockchain Data: Permanent and immutable by design.

Upon account deletion, we anonymize or delete all off-chain personal data within 30 days, except where retention is required by law.

8. Cookies & Tracking Technologies

We use cookies and similar technologies to operate our services:

• Essential Cookies: Required for basic functionality — session management, authentication, security, and load balancing. Cannot be disabled.
• Functional Cookies: Remember preferences like language, theme, and display settings. Activated with your consent.
• Analytics Cookies: Help us understand traffic patterns and user behavior. Anonymized where possible. Activated with your consent.
• Marketing Cookies: Used to measure advertising effectiveness. Only activated with your explicit consent.

You can manage cookie preferences through the cookie consent banner shown on your first visit, or by adjusting your browser privacy settings. Disabling certain cookies may affect platform functionality.

We use localStorage to store your cookie consent preference (key: unp_cookie_consent) and essential wallet session data.

9. Data Security

We implement robust security measures to protect your data:

• Encryption: TLS 1.3 for data in transit. AES-256 encryption for sensitive data at rest.
• Access Control: Role-based access control (RBAC) with multi-factor authentication for internal systems.
• Key Management: Private keys in the Unipoly Wallet are encrypted locally and never transmitted to our servers.
• Infrastructure: Enterprise-grade cloud hosting with SOC 2 compliance, regular penetration testing, and DDoS mitigation.
• Monitoring: 24/7 intrusion detection, automated anomaly alerts, and incident response protocols.
• Smart Contract Audits: All OCAP and DeFi smart contracts undergo third-party security audits.

10. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

• Access: Request a copy of all personal data we hold about you.
• Rectification: Correct inaccurate or incomplete personal data.
• Erasure: Request deletion of your personal data ("right to be forgotten"), subject to legal retention obligations.
• Restrict Processing: Request limitation of data processing in certain circumstances.
• Data Portability: Receive your data in a structured, machine-readable format.
• Object: Object to processing based on legitimate interests, including direct marketing.
• Withdraw Consent: Revoke consent at any time without affecting prior processing.
• Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise any right, email privacy@unpchain.com with your request. We respond within 30 days.

For comprehensive GDPR rights information, visit our GDPR Compliance page.

11. Children's Privacy

Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If you are a parent or guardian and learn that your child has provided personal data to us, please contact us at privacy@unpchain.com and we will promptly delete such data.

12. Third-Party Links & Services

Our platforms may contain links to third-party websites, services, or integrated applications (e.g., payment gateways, NFT marketplaces, analytics providers). We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before sharing any personal data.

Specific third-party integrations include:

• Razorpay: Payment processing for fiat transactions within Digital Banking.
• OpenStreetMap: Map tiles for location-based services like UniHunt.
• CKEditor: Rich text editing in Creator Studio.

13. Wallet & Private Key Privacy

Your Unipoly Wallet is designed with privacy-first principles:

• Non-Custodial: Your private keys and seed phrases are generated and stored locally on your device. We never have access to them.
• Encryption: Wallet data is encrypted using your personal passcode or biometric authentication.
• No Recovery: Because we do not store your private keys, we cannot recover lost keys or restore access. You are solely responsible for backing up your seed phrase.

14. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or services. When we make material changes:

• We will post a prominent notice on our website.
• We will send email notification to registered users for significant changes.
• The "Effective" date at the top of this page will be updated.

Continued use of our services after changes constitutes acceptance of the updated policy. We recommend reviewing this policy regularly.

15. Contact Us

For any privacy-related questions, concerns, or data subject access requests: