Legal

Privacy Policy

Effective as of: June 3rd, 2026

This Privacy Policy describes how PokemonFM Ltd.("Company", "we", "us" or "our") and our affiliates handle personal information that we collect through our digital properties that link to this Privacy Policy, including our website (collectively, the "Service"), as well as through social media, our marketing activities, live events, and other activities described in this Privacy Policy.

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

  • Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.
  • Demographic data, such as your city, state, country of residence, postal code, and age.
  • Profile data, such as the wallet address and username or display name used to establish an account on the Service, links to your profiles on social networks, and any other information that you add to your account profile.
  • Communications that we exchange with you, including when you contact us through the Service, social media, or otherwise.
  • Transactional data, such as blockchain transaction history, pack openings, draw entries, and information relating to or needed to complete your purchases, sales, redemptions, or withdrawals on or through the Service.
  • User-generated content, such as profile pictures, comments, questions, messages, and other content that you generate, transmit, or otherwise make available on the Service, as well as associated metadata.
  • Financial data, such as your virtual currency or wallet accounts, balances, fees, sale prices, and associated details.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

  • Public sources, such as government agencies, public records, social media platforms, public blockchain(s), and other publicly available sources.
  • Data providers, such as information services and data licensors that provide demographic and other information.
  • Marketplaces and game studios that provide information allowing us to operate the Service.
  • Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs.
  • Marketing partners, such as joint marketing partners and event co-sponsors.
  • Third-party services that you use to log into, or otherwise link to, your Service account.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications, and other online services, such as:

  • Device data, such as your computer's or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, device type, IP address, unique identifiers, language settings, mobile device carrier, network information, and general location information such as city, state, or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, access times and duration of access, and whether you have opened our emails or clicked links within them.
  • Location data when you authorize the Service to access your device's location.

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

  • Cookies, which are small text files that websites store on user devices and that allow web servers to record users' web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include "session cookies", "persistent cookies", "first party" cookies, and "third party" cookies placed by our business partners and service providers.
  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed, or that certain content was viewed or clicked.
  • Software development kits that we may incorporate into our applications for analytics, social-media integration, additional features, or to facilitate online advertising.

Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery. We may use your personal information to:

  • provide, operate, and improve the Service and our business;
  • establish and maintain your user profile and your history of activity on the Service;
  • facilitate your invitations to friends you want to invite to join the Service;
  • enable security features of the Service and remember devices from which you have previously logged in;
  • communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
  • understand your needs and interests and personalize your experience with the Service and our communications;
  • provide support for the Service and respond to your requests, questions, and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business.

Marketing. We, and our service providers, may collect and use your personal information for direct marketing communications. You may opt out of our marketing communications as described in the Your choices section below.

Compliance and protection. We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
  • protect our, your, or others' rights, privacy, safety, or property (including by making and defending legal claims);
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies;
  • enforce the terms and conditions that govern the Service; and
  • prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use, or share your personal information, such as when required by law.

To create anonymous, aggregated, or de-identified data. We may create anonymous, aggregated, or de-identified data from your personal information and that of other individuals. We may use and share this data with third parties for our lawful business purposes.

Cookies and similar technologies may additionally be used for:

  • Technical operation — to allow the technical operation of the Service, such as remembering your selections and preferences and whether you are logged in.
  • Analytics — to help us understand user activity on the Service.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research, and website analytics).

Game studios and content partners. We may share your personal information with third-party studios or content partners to facilitate game sessions, pack openings, or other features you initiate through the Service.

Cryptocurrency or payment platforms. Any information necessary to process a purchase or withdrawal (such as your wallet address) is processed by the relevant cryptocurrency or payment platform. Please review the privacy policies for the relevant platform to learn how they may use your payment information.

Linked third-party services. If you log into the Service with another third-party service, we may share your personal information with that service. The third party's use of the shared information will be governed by its privacy policy and the settings associated with your account on that service.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above, including the Anjouan Gaming Authority and the Lao PDR gaming regulator on lawful request.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, Company or our affiliates (including, in connection with a bankruptcy or similar proceeding).

Other users and the public. Your profile and other user-generated content (except for private messages) may be visible to other users of the Service and the public. This information can be seen, collected, and used by others, including being cached, copied, screen captured, or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

Your choices

Access or update your information. If you have registered for an account, you may review and update certain account information by logging into the account.

Opt-out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at support@pokemonfm.com. Please note that if you choose to opt out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms. If you choose to connect to the Service through another third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Other Sites and Services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications, or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

Security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We and our service providers may operate in jurisdictions other than yours. Your personal information may be transferred to locations where privacy laws may not be as protective as those in your state, province, or country.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to contact us

Email: support@pokemonfm.com

Data controller: PokemonFM Ltd.