Privacy Policy

1. Introduction

Clixor ("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 our skill-based gaming platform.

By using Clixor, you consent to the data practices described in this policy.

2. Information We Collect

2.1 Personal Information You Provide

Account Registration:

• Email address
• Username
• First and last name
• Date of birth (age verification)
• Country and region (location)
• Password (encrypted)

Payment Information:

• PayPal account information (processed by PayPal, not stored by us)
• Transaction history
• Deposit and withdrawal records

KYC Verification (required for all deposits and withdrawals):

• Government-issued ID (passport, driver's license, national ID)
• Selfie/photo verification (liveness check)
• Processed by Sumsub (third-party KYC provider)
• Verification must be completed before first deposit or withdrawal

2.2 Automatically Collected Information

Usage Data:

• Gameplay statistics (scores, match history, win/loss records)
• Tournament participation and results
• Login/logout times
• Feature usage patterns

Device Information:

• Device type and model
• Operating system and version
• Browser type and version
• IP address
• Device identifiers (for fraud prevention)

Location Data:

• Country and region (from IP address)
• Used for compliance and fraud prevention
• Not precise GPS location

2.3 Cookies and Tracking Technologies

Important: Cookies are ONLY used on our website (omarela.com) for deposits, withdrawals, and viewing legal documents. The mobile app does NOT use cookies.

Website Cookies (omarela.com only):

• Essential Cookies: Authentication, security, session management for payment processing
• Preference Cookies: Language, settings, customization

We do NOT use:

• ❌ Analytics cookies (no Google Analytics, no tracking)
• ❌ Advertising cookies
• ❌ Third-party tracking cookies
• ❌ Social media cookies

You can control cookies through browser settings, but essential cookies are required for payment processing.

3. How We Use Your Information

3.1 Primary Purposes

Service Delivery:

• Create and manage your account
• Process transactions and payments
• Enable tournament participation
• Display leaderboards and rankings
• Provide customer support

Legal Compliance:

• Age verification (18+ requirement)
• KYC/AML compliance
• Tax reporting (if required)
• Fraud prevention and detection
• Comply with legal obligations

Platform Improvement:

• Analyze usage patterns
• Improve game performance
• Develop new features
• Fix bugs and errors
• Optimize user experience

3.2 Legal Basis for Processing (GDPR)

We process your data based on:

• Contract Performance: Necessary to provide services
• Legal Obligation: KYC/AML compliance, age verification
• Legitimate Interest: Fraud prevention, platform improvement
• Consent: Marketing communications, optional features

4. How We Share Your Information

4.1 Third-Party Service Providers

Payment Processing:

• PayPal: Payment processing for deposits and withdrawals
• Handles secure payment transactions
• Subject to PayPal's privacy policy
• Transactions processed on our secure website (omarela.com/clixor/deposit and omarela.com/clixor/withdraw)

KYC Verification:

• Sumsub: Identity verification
• Processes ID documents and biometric data
• Subject to Sumsub's privacy policy

Infrastructure:

• Vercel: Hosting and content delivery
• Upstash Redis: Data caching and session management
• Supabase/PostgreSQL: Database services
• Cloudflare: CDN and DDoS protection

4.2 Public Information

Leaderboards and Rankings:

• Username and scores are publicly visible
• Match history may be visible to other users
• You can request username changes for privacy

We do NOT share:

• Email addresses
• Payment information
• Personal identification documents
• Precise location data

5. Data Security

5.1 Security Measures

Technical Safeguards:

• TLS/SSL encryption for data transmission
• AES-256 encryption for data at rest
• Secure password hashing (bcrypt)
• Regular security audits and penetration testing
• Firewall and intrusion detection systems

Payment Security:

• PCI DSS compliant payment processing (via PayPal)
• No storage of payment credentials
• Secure redirect to PayPal for all transactions
• Web-based payment flow for enhanced security

5.2 Your Responsibilities

• Keep your password confidential
• Use strong, unique passwords
• Enable two-factor authentication (when available)
• Report suspicious activity immediately
• Log out from shared devices

6. Your Privacy Rights

6.1 Rights for All Users

• Access: Request copy of your personal data
• Rectification: Correct inaccurate information
• Deletion: Request deletion of your data (subject to legal requirements)
• Objection: Object to certain processing activities
• Portability: Receive your data in machine-readable format
• Withdraw Consent: Opt-out of marketing communications

How to Exercise Rights:

• Email: privacy@omarela.com
• In-app: Settings → Privacy → Data Rights
• Response time: 30 days maximum

6.2 GDPR Rights (EU/EEA Users)

Additional Rights:

• Right to restriction of processing
• Right to lodge complaint with supervisory authority
• Right to object to automated decision-making
• Right to be forgotten (with exceptions)

6.3 CCPA Rights (California Users)

California Consumer Privacy Act Rights:

• Right to know what data is collected
• Right to know if data is sold or shared
• Right to delete personal information
• Right to opt-out of data sales (we do not sell data)
• Right to non-discrimination for exercising rights

7. Data Retention

7.1 Retention Periods

• Active Accounts: Account data retained while account is active
• Transaction History: 7 years (legal requirement)
• Gameplay Data: Indefinitely for leaderboards and statistics
• Inactive Accounts: 3 years after last login, then anonymized or deleted
• Deleted Accounts: Personal data deleted within 30 days

8. Children's Privacy

• Platform strictly for users 18 years and older
• We do not knowingly collect data from minors
• Age verification required during registration
• If you believe a minor has provided information, contact us immediately: privacy@omarela.com

9. International Data Transfers

As we operate globally, your information may be transferred to and processed in countries outside your residence, including the Netherlands (EU), United States, and other jurisdictions where our service providers are located.

9.1 EU-US Data Transfers

• We comply with GDPR requirements for international transfers
• Standard Contractual Clauses (SCCs) used with non-EU processors
• Adequate safeguards in place for all transfers

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be effective immediately upon posting. We will notify you of material changes via:

• Email notification to registered users
• In-app notification
• Prominent notice on our website

Your continued use of the Platform after changes constitutes acceptance of the updated Privacy Policy.

11. Contact Information

Privacy Inquiries:
Email: privacy@omarela.com
Data Rights: privacy@omarela.com
Security Issues: security@omarela.com

General Support:
Email: support@omarela.com
Response time: 24-48 hours

Postal Address:
Clixor - Omarela Platform
Rotterdam, The Netherlands

Data Protection Officer:
Email: dpo@omarela.com