Privacy Policy

Last Updated: December 6, 2025

1. Introduction

Galaxia Sports ("we", "us", "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Galaxia Sports Platform.

2. GDPR Compliance (EU Users)

If you are located in the European Economic Area (EEA), you have certain rights under the General Data Protection Regulation (GDPR):

• Right to Access: You can request a copy of your personal data
• Right to Rectification: You can correct inaccurate data
• Right to Erasure: You can request deletion of your data (subject to legal retention requirements)
• Right to Restrict Processing: You can limit how we use your data
• Right to Data Portability: You can receive your data in a structured format
• Right to Object: You can object to certain processing activities

To exercise these rights, contact us at privacy@galaxia.sports

3. Information We Collect

3.1 Personal Information

• Identity information (name, date of birth, government ID)
• Contact information (email, address, phone number)
• Financial information (payment methods, transaction history)
• KYC/AML documentation (ID documents, proof of address)
• Wallet addresses and blockchain transaction data

3.2 Technical Information

• IP address and geolocation data
• Device information and browser type
• Usage data and analytics
• Cookies and similar tracking technologies

4. How We Use Your Information

We use your information for:

• Service Provision: To provide and maintain the Platform
• KYC/AML Compliance: To verify identity and comply with regulatory requirements
• Transaction Processing: To process transactions and payments
• Security: To detect and prevent fraud, money laundering, and other illegal activities
• Legal Compliance: To comply with applicable laws and regulations
• Communication: To send important updates and respond to inquiries

5. Legal Basis for Processing (GDPR)

We process your personal data based on:

• Contractual Necessity: To fulfill our contract with you
• Legal Obligation: To comply with KYC/AML and other regulatory requirements
• Legitimate Interests: For fraud prevention and security
• Consent: Where you have provided explicit consent

6. Data Sharing and Disclosure

We may share your information with:

• Regulatory Authorities: As required by law (e.g., SAR filings, regulatory reports)
• Service Providers: Third-party services for KYC verification, sanctions screening, payment processing
• VASPs: Other Virtual Asset Service Providers for Travel Rule compliance
• Legal Requirements: In response to court orders, subpoenas, or legal processes

We do not sell your personal information to third parties.

7. Data Retention

We retain your data for:

• Transaction Records: Minimum 5 years (AML requirement)
• KYC Records: Minimum 5 years after account closure
• Audit Logs: 7 years for compliance and security purposes

Data may be retained longer if required by law or for ongoing legal proceedings.

8. Cross-Border Data Transfers

Your data may be transferred to and processed in countries outside your jurisdiction. We ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) for EU data transfers.

9. Data Security

We implement technical and organizational measures to protect your data:

• Encryption at rest and in transit (TLS 1.3+)
• Access controls and authentication
• Regular security audits and penetration testing
• Incident response procedures

10. Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will:

• Notify relevant supervisory authorities within 72 hours (GDPR requirement)
• Notify affected users without undue delay
• Provide details of the breach and mitigation measures

11. Cookies and Tracking

We use cookies and similar technologies. See our Cookie Policy for details. You can manage cookie preferences in your browser settings.

12. Children's Privacy

The Platform is not intended for users under 18 years of age. We do not knowingly collect information from children.

13. Your Rights

Depending on your jurisdiction, you may have rights to:

• Access your personal data
• Correct inaccurate data
• Delete your data (subject to legal requirements)
• Export your data
• Object to processing
• Withdraw consent

14. Contact Us

For privacy inquiries or to exercise your rights:

Data Protection Officer
Galaxia Sports
Email: privacy@galaxia.sports
Address: [Registered Address]

15. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified to users. Continued use of the Platform after changes constitutes acceptance of the updated policy.