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ZYVORA LAND – PRIVACY POLICY

At Zyvora Land (“Zyvora,” “we,” “us,” or “our”), we value your privacy and the trust you place in us. This Privacy Policy explains what data we collect, why we collect it, how we use it, and the choices you have. It applies to zyvoraland.com (including any subdomains, successor sites, or apps that link to this policy) and to the products and services available through it (collectively, the “Website”).

By visiting or using the Website, you acknowledge that you have read and agree to this Privacy Policy. If you do not agree, please discontinue use of the Website.

This policy covers information we collect:

  • On the Website;
  • Through email, text, live chat, and other electronic messages between you and the Website;
  • Via mobile or desktop applications that provide non-browser interactions with the Website; and
  • When you engage with our ads or applications on third-party services that link to this policy.

This policy does not cover information collected:

  • Offline or by any channel not described above; or
  • By third parties (including content and applications) that may link to or be accessible from the Website.

We may update this Privacy Policy from time to time (see Changes to This Privacy Policy). Your continued use of the Website after we post changes signifies your acceptance of the revised policy.

1) DATA CONTROLLER

This Privacy Policy is issued on behalf of Zyvora Land. When we say “Zyvora,” “we,” “us,” or “our,” we refer to the Zyvora entity responsible for processing your personal data.

2) WHAT WE COLLECT & HOW LONG WE KEEP IT

Types of data. We collect personal information, anonymous information, and may derive aggregate information from those (see Definitions below). Examples include:

  • Contact details: name, email address, postal address, phone numbers.
  • Profile & demographics: age (or age range), gender, profile images.
  • Account credentials: username, password, profile pictures.
  • Transactions & support: payment/redemption info (e.g., card/bank details), shipping/billing address, communications with support.
  • Communications: messages via text, live chat, posts, or similar channels.
  • Third-party signals: data from platforms (e.g., social networks) about your use of or interest in our services.
  • Location data: device-based location or location inferred from IP, where permitted by law.
  • Device/usage data: pages viewed, session times, frequency of use, referral sources, preferences, hardware model, OS/browser type, IP address, and other identifiers.
  • Regulatory/KYC: where required by law, government-issued IDs or similar identifiers to verify identity, meet AML/CTF obligations, or satisfy tax requirements.

Retention. We keep data only as long as necessary for the purposes described here or as required/permitted by law. For UK residents, the following table summarizes categories (as defined under UK law) collected or processed in the last 12 months and our intended retention period:

  • A. Identifiers (name, alias, address, email, phone, account name, IP, government IDs): Collected: Yes — Retention: 3 years (account administration, legal and operational needs).
  • B. Personal & financial information (bank/card details, limited employment/education if provided for verification, insurance numbers if applicable, health data if legally required): Collected: Yes — Retention: 3 years (contract, audits, legal compliance).
  • C. Special category data (e.g., ethnicity, beliefs, union membership, biometric/health, sexual orientation), processed only when lawful: Collected: Yes, where lawful — Retention: 3 years (consent/legal obligation/legitimate interest).
  • D. Commercial information (products/services purchased, considered, usage preferences): Collected: Yes — Retention: 3 years (analytics, CRM, service improvement).
  • E. Biometric/genetic (e.g., fingerprints, iris scans, DNA): Collected: No.
  • F. Online activity (browsing/search history, ad interactions, app usage): Collected: Yes — Retention: 3 years (service and site enhancement).
  • G. Location data (GPS/device-based, movement patterns): Collected: Yes — Retention: 3 years (location features, logistics).
  • H. Sensory data (audio/video/thermal/olfactory): Collected: No.
  • I. Employment/professional data: Collected: No.
  • J. Educational data: Collected: No.
  • K. Inferences/profiles (preferences, traits, behavior patterns): Collected: No — Retention: 3 years (personalization/service improvement, where applicable).

3) HOW WE COLLECT DATA

We obtain information you provide directly (e.g., when you register, make purchases, fill forms, participate in surveys/promotions, or contact us by phone, video, email, live chat, text, social media). Calls with Zyvora representatives may be recorded for training, quality, and compliance. By continuing a recorded call, you consent to that recording.

We also collect data automatically via technologies present on our Website or apps (see Personal Data Collected via Technology below), and we use analytics tools. We may supplement or validate data with trusted third-party sources (e.g., address verification).

4) HOW WE USE DATA

The Data Controller processes your data for the purposes below; Zyvora affiliates may act as processors where they support these purposes.

  • Provide & manage services: register and maintain your account; perform fraud/abuse checks.
  • Improve support & services: respond to requests; use feedback to enhance features and offerings.
  • Process payments/redemptions: fulfill orders and meet KYC/AML (“source of funds” where relevant).
  • Personalize experiences: analyze aggregated usage to better understand how the Website is used.
  • Communicate with you: about accounts, promotions, surveys, features, contests; manage marketing preferences (see Rights in Direct Advertising).
  • Send important notices: transactional messages, policy/terms updates, and similar—these are service communications you may not be able to opt out of.
  • Meet legal/regulatory duties: responsible social gaming assessments, tax reporting, AML/fraud prevention, enforcement of terms, and legal processes.
  • Alternative dispute resolution: share necessary data with our ADR partner to resolve unresolved disputes.

We do not engage in automated decision-making within the meaning of European data-protection laws.

5) PERSONAL DATA COLLECTED VIA TECHNOLOGY

We and our partners use standard technologies (e.g., cookies, pixels/web beacons, mobile identifiers, event tags/APIs) to remember preferences, measure engagement, improve performance, and deliver/measure ads. You can block or delete cookies in most browsers, though some features may not work properly if you do.

We may engage in interest-based advertising with third-party partners. They may use cookies and similar tools across sites/apps to infer your interests and show relevant ads. We do not control those third parties’ technologies; for questions, contact the responsible third party.

6) YOUR RIGHTS

Subject to applicable law, you may have rights to: access, rectify, erase, restrict, object, and port your personal data, and to withdraw consent where processing is based on consent. These rights are not absolute and may be limited by legal obligations.

  • Supervisory authority: You may complain to your local data-protection authority.
  • Direct advertising: You may object at any time to processing for direct marketing (including related profiling). If you object, we will stop processing your personal data for these purposes.
  • Opt-out preference signals: You can manage non-essential data collection via browser/device settings (e.g., Global Privacy Control). Blocking cookies may limit site functionality.
  • Interest-based ads: Region-specific opt-out mechanisms may apply (see your browser/device settings or industry tools).

UK Data Subject Rights (UK GDPR & DPA 2018). You may request:

  1. Access to your data and processing details;
  2. Rectification of inaccurate/incomplete data;
  3. Erasure where appropriate;
  4. Restriction in certain cases;
  5. Objection to processing (e.g., direct marketing/legitimate interests);
  6. Portability where applicable.

Verification & how to submit a request.

To exercise rights, we must verify your identity and, where relevant, residency. Please provide sufficient details for us to locate your records and process your request.

  • Email: **[email protected]**
  • We aim to respond within one month. Complex or numerous requests may be extended by up to two additional months; we will notify you if so.
  • Authorized representatives: You may appoint one with written authorization; we may request evidence of that authorization.
  • Fees: We do not charge unless requests are excessive, repetitive, or manifestly unfounded.
  • Appeals: Where available by law, you can appeal our response by emailing **[email protected]; we’ll reply within 45 days** with information on further recourse where applicable.
  • Account updates: Registered users can update certain account details in their profile settings.
  • Non-discrimination: We will not discriminate against you for exercising your rights.

Data deletion requests. For security, we require identity verification before processing account deletion. Verification may involve email, phone, or other secure methods.

7) HOW WE PROTECT DATA

We use physical, technical, and organizational safeguards to protect information against unauthorized access, use, alteration, disclosure, or destruction. Security practices are reviewed and updated periodically. You are responsible for maintaining the confidentiality of your password and account credentials.

No method of transmission over the Internet is 100% secure. We cannot guarantee absolute security, and any transmission is at your own risk.

8) SHARING YOUR INFORMATION

We do not sell, trade, or rent personal information. We share data only as described below:

  • Within Zyvora group: With Zyvora affiliates for the purposes described here (see Transfers).
  • Service providers: With trusted vendors who perform services for us (e.g., hosting, storage, analytics, payments, KYC/AML, marketing support). They may only use personal data as instructed or as required by law.
  • With your consent: Where you direct or authorize us to share.
  • Regulatory/legal: To comply with lawful requests, legal processes, and regulatory inquiries; to protect our rights, users, or others; enforce terms; or detect/prevent fraud/illegal activity.
  • Transactions: In connection with mergers, acquisitions, restructurings, or asset transfers.
  • Financial institutions/regulators: To complete transactions or meet AML/CTF and similar obligations, including “source of funds” verification.
  • Identity verification: We may request images for verification. Third-party providers (e.g., Sumsub) may process biometric data from your image to match your photo to your ID. Such data is stored by the provider under its policy and by us until the initial purpose is fulfilled or up to 3 years from your last interaction, unless law requires longer retention.

Categories disclosed in past 12 months (UK GDPR):

  • A. Identifiers: merchants, identity-verification providers, game providers (to verify eligibility).
  • B. Contact/Account: merchants, identity-verification providers (to facilitate transactions/verification).
  • C. Protected characteristics: identity-verification providers where required by law.
  • D. Commercial information: merchants (to process purchases/redemptions).
  • E–K: Not collected or not disclosed as specified above.

Aggregated data. We may share aggregated or de-identified insights that cannot reasonably identify you.

Transfers. We operate internationally. Personal data may be processed in the EU or other countries where we or our providers operate. Where required, we use appropriate safeguards (e.g., Standard Contractual Clauses) or other lawful transfer mechanisms to protect your data.

9) CHILDREN’S PRIVACY

Our services are for individuals 18+. We do not knowingly collect information from anyone under 18. If we learn we have collected data from a minor, we will delete it. If you believe a child has provided data to us, contact **[email protected]**.

10) DO-NOT-TRACK

At this time, there is no industry consensus on responding to browser “Do-Not-Track” signals, and the Website does not act on them. We will reassess if standards emerge.

11) CHANGES TO THIS PRIVACY POLICY

We may revise this policy to reflect changes in our practices or legal requirements. Where required, we will notify you and, if necessary, obtain your consent. Updates are effective when posted on the Website. Please review periodically.

12) DEFINITIONS

  • Personal information: Data that identifies or can reasonably be linked to a specific person (e.g., name, address, email, phone). When anonymous data is linked to personal data, it is treated as personal information.
  • Anonymous information: Data that cannot reasonably identify an individual, directly or indirectly.
  • Aggregate information: Compiled data about groups or categories of users that does not identify an individual.

13) CONTACTING YOU VIA EMAIL OR TEXT

By providing your contact details, you confirm they are accurate and that you are the subscriber/authorized user. You consent to receive autodialed or prerecorded calls and text messages from or on behalf of Zyvora Land regarding: (i) this Privacy Policy and related terms; (ii) your account/transactions; and (iii) Zyvora promotions. Carrier charges may apply. You may adjust your marketing preferences at any time (see Rights in Direct Advertising).

14) CONTACT US

For questions about this Privacy Policy or your personal data, contact our Data Protection Officer:

Email: **[email protected]**

Please include your place of residence and a brief description of your request.