Privacy

This notice covers the data used to run The Cipher specifically. The data controller for this promotion is xPortal Equity AG (Liechtenstein). It sits alongside the main xPortal privacy policy, which continues to apply to your use of the app.

What we use

• Your wallet address. Used to record that you joined, to check whether a challenge was completed, and to send a prize if you win.
• Your qualified volume per week, as computed by the backend under the published caps - used only to rank the leaderboard and settle prizes.
• The time a challenge was completed, only because some prizes depend on being among the first to finish a week.

Where this data comes from: your wallet address and challenge completion come from your use of the xPortal app; your qualified volume is computed by our backend from records of the qualifying actions you take in the app (on-ramp purchases, swaps, card spending). Card-spending data is processed with our regulated partners that provide those services.

What we do not do

• We do not publish your full wallet address. Winners are shown shortened, for example erd1a2b...9f4c.
• We do not publish names, balances, portfolio contents or transaction history.
• The public leaderboard shows the top 10 by shortened address and ranking only - never full addresses, names, balances or transaction detail.
• We do not sell your data or share it with advertisers.

Who we share it with

We share the minimum data necessary with: our technology and hosting providers that operate this promotion page and backend; our group companies involved in running the promotion and paying prizes; and, where required, our regulated payment and crypto-service partners and the tax authorities. We require our providers to process data only on our instructions. We do not sell your data or share it with advertisers.

Why we are allowed to use it

We rely on the following legal bases: performance of the arrangement between us, to run the competition you entered and pay prizes; our legitimate interests, to select the free visitor draw, verify fair play and prevent fraud or manipulation; and compliance with legal obligations, such as tax and accounting record-keeping. Leaderboard ranking and prize eligibility are determined automatically from the published rules; if you believe a result is wrong, you may contest it as described in the Official Rules and ask for human review.

The free visitor draw

If you connect a wallet on this page but do not enter the competition, we record your wallet address to include you in the free weekly visitor draw. We use it only to run and settle that draw.

How long we keep it

We keep participation records for the duration of the promotion and for as long as needed afterwards to resolve any disputes, and to meet tax and accounting obligations - typically up to the statutory retention period applicable to such records. Data written to a public blockchain cannot be deleted.

A note on the blockchain

Prize payments are on-chain transactions. Anything recorded on a public blockchain is public and permanent, and cannot be deleted or amended by us or by anyone else.

International transfers

The controller is established in Liechtenstein (EEA). Where any provider processes data outside the EEA, we put in place an appropriate transfer mechanism (such as the European Commission’s standard contractual clauses).

Cookies and analytics

This page may use strictly necessary and analytics technologies to operate and measure the promotion. Where analytics are not strictly necessary, we rely on your consent, which you can withdraw at any time. Cookies usage is done in accordance with the conditions described at xportal.com/privacy.

Your rights

You have the right to access your data, to have it corrected or deleted, to object to or ask us to restrict certain processing, and to receive the data you provided in a portable format. These rights have limits - we may need to keep some records for legal reasons, and nothing written to a blockchain can be removed. You can also complain to the data protection authority in your EEA country of residence.

Contact

To exercise your rights or ask about this notice, contact our team through support in the xPortal app or via the xPortal Help Center at help.xportal.com.