PRIVACY POLICY

Last updated 12thJuly 2023

1. Forword

ChopSquad is a fantasy gaming competition platform where football enthusiasts (“you”, or “user”) can compete with others for a cash price using their favorite football athletes. We value and regard your privacy and are committed to providing a safe environment for our user’s experience.

This Privacy Policy describes how ChopSquad ("we," "us," or"our") collects, uses, protects, and shares (“PROCESS”) the personal information of users ("you" or "your") who participate in our fantasy Premier League product such as when you: Visit our website at chopsquadapp.webflow.io and any product of ours that links to this privacy notice: Engage with us in other related ways, including but not limited to sales, marketing, or events.

Questions or concerns? Reading this privacy notice helps you understand your privacy rights and choices. If you do not agree with our policies and practice, pleasedo not use our services. If you still have any questions or concerns, please contact us at getchopsquad@gmail.com. Please read this Privacy Policy carefully to understand our practices regarding your personal information.

2. Information Collected and Reasons

We collect and process a very minimal amount of personal information that you voluntarily provide to us when you register on the platform for reasons such as, user experience improvement, ease of use of platform and fraud prevention. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following.

2.1  Personal Information

This section clearly highlights the type ofPersonal Data we collect, we process and the reason for it.

• User Account Information

ChopSquad collects and processes personal data toallow users to create and access their account on the platform. The personalinformation that we collect depends on the context of your interactions with usand the Services, the choices you make, and the products and features you use.To handle your user account from creation to deletion, we must collect some ofyour personal information which include:

• First name
• Last name
• Email address
• Username

You will also be able to store your personal settings and preferences on your general User account and/or through your device. In order to store these, ChopSquad will associate your choices with your User account, technical identifiers, and/or device.

• Use of Services

ChopSquad obtains and handles personal data to enable your access and utilization of various aspects of the Services. This includes facilitating wallet funding, withdrawals, playing the Game, and engaging in our Referral Programs.

• Fundingand Withdrawal

To enable funding and/or withdrawals through our Services, ChopSquad collects your username, wallet public key or payment identifier, and has limited access to a portion of your credit card number (specifically, the last four digits, which we receive indirectly from payment service providers and do not directly collect orstore).

• Tournament Participation

To facilitate your participation in tournaments, award prizes to winners, and publish leaderboards, ChopSquad processes your username, wallet public key, and the prizes you have won (if applicable). As part of presenting tournament results, ChopSquad may publish your username and the prizes you have won on its Website and Mobile application.

• Affiliate or Referral Programs

ChopSquad collects and processes your email address, username, and wallet public key to enable participation in our Referral programand/ or communicate with you regarding participation in the Fantasy PremierLeague

• User Inquiries and Communication

When handling and addressing your inquiries or requests submitted through our contact center or other means, ChopSquad collects and handles personal data, including your username, contact information, and the content of your message (if it contains personal data).

2.2  Non-Personal Information

ChopSquadmay also collect non-personal information. This information is used for analytical purposes to improve our services and enhance the user experience. This information may also be shared with third-party service providers who assist usin operating our business. This section clearly highlights thetype of Non-Personal Information we collect and process and the reason for it.

• Use of Website and Mobile Application

ChopSquad gathers andanalyzes certain data to better understand and gain insights into how users engage with our services and enhance their overall experience. This informationen compasses diverse browsing details obtained from cookies or technical identifiers on mobile devices (please refer to our Cookie Policy). Some of this information may contain personal data.

• Compliance with Terms; Website and Account Security

ChopSquad gathers specific device and browser details (user agent), browsing data, including IP address (which can provide information about your country/statelocation), account information (including your email address), and transaction specifics to uphold the security of the Services and your user account.

This data is utilized to detect, prevent, investigate, and trace any attempts to violate our Terms and Conditions or any other applicable terms, such as malicious hacking.

During an investigation, ChopSquad may implement additional security measures, such as requesting additional supporting documents or information, suspending, or canceling the relevant transaction if verification cannot be established.

In cases of confirmed payment fraud, the relevant dataand associated information will be stored in ChopSquad's monitoring system forfuture verifications.

4. Data Sharing and Disclosure

ChopSquad engages with third-party service providers and suppliers to assist in fulfilling the purposes outlined in this policy.

• Third-Party Services

Certain content or features of the website and/or app are provided by these third-party service providers. To ensure your access to such content and/or features, ChopSquad may share some of your personal data with these third-party services and suppliers.

The third-party service providers may request additional datafrom you. Whether integrated directly into the website and/or app or not, these third-party services collect and process any data they receive in accordance with their respective privacy policies, for which they hold soleresponsibility.

It is important to note that the contractual agreements between ChopSquad and our third-party service providers (such as payment services providers or marketing partners) specify that both ChopSquad and the third-party service providers actas "independent controllers" as defined by data protection laws and regulations (NDPR).

Both parties are required to comply with applicable data protection laws and regulations. For more information, please refer to the privacy policy of the relevant third-party service. Additionally, in connection with a business transaction, such as a merger, acquisition, or sale of assets, your personal information may be transferred to a new entity.

Please note that the sharing of data with third-party service providers is done in accordance with applicable privacy laws and regulations, and appropriate measures are taken to safeguard the confidentiality and security of the shared data.

• Governmental and Judicial Purposes

ChopSquad may disclose your personal data to competent courts, governmental, and public authorities in accordance with the law orvalid court orders, to the extent permitted by applicable legal requirements. We prioritize the confidentiality and security of your data when sharing it with these recipients. Such sharing is strictly limited to what is necessary and relevant for fulfilling the specified processing purposes

5. Data Retention

We only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period isrequired or permitted by law (such as tax, accounting, or other legal requirements).

No purpose in this notice will require us to keep your personal information for longer than the period in which users have an account with us.

When we have no on-going legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. Use by Children

ChopSquad is not intended for use by children under the age of 18. We do not knowingly collect personal information from individuals under 18 years of age. If we become aware that we have collected personal information from a child without parental consent, we will take steps to delete that information.

7. Deletion of Account

If you wish to delete your account and have your personal information removed fromour system, please contact us using the information provided at the end of this document.

We will process your request in accordance with applicable laws and promptly delete your account and associated personal information, except as otherwise required by law. At ChopSquad, safeguarding your Personal Data and adhering to the relevant data protection regulations are top priorities.

We can only achieve this by working together. By accepting this Policy, you agree to maintain accurate and current Personal Data on ChopSquad and ensure its up-to-date nature.

Furthermore, if you provide us with any information that could identify other individuals, either directly or indirectly, you confirm that you have informed those individuals about this Policy and, where applicable, obtained their consent for the processing of their data.

8. User Privacy Rights

In some regions like the EEA or UK or NIGERIA, you have certain rights under applicable data protection laws. These may include the right:

(I) to request access and obtain a copy of your personal information,
(II) to request rectification or erasure;
(III) to restrict the processing of your personal information, and
(IV) if applicable, to data portability.

In certain circumstances, you mayalso have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the Privacy policy below.

We will consider and act upon any requestin accordance with applicable data protection laws. If you are in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority.

• Withdrawing Your Consent

We rely on your consent to process your personal information, which may be expressed and/or implied consent depending on the applicable law.

You have the right to withdraw your consent at any time. You can withdraw your consent by any time by contacting us by using the contact details provided in the Privacy policy below. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

• Accounts Information

If you would at any time like to review or change the information in your account or terminate your account, you can Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

9. Cookies

Cookies are small text files of information that are placed on a user's device by thewebsite's server. They serve to transmit information from the website to the user's browser and enable the browser to send information back to the original website. For instance, this can include a session identifier or language preference.

There are different types of cookies, including: 

• Session cookies, which are deleted as soon as you leave the website.
• Permanent cookies, which remain on your device until they expire or are deleted using your browser's functionalities.

Please be aware that when you visit the website, cookies may be placed on your device. We use cookies and similar technologies to enhance your experience on our website. You can manage your cookie preferences through your browser settings. Please note that disabling cookies may affect certain features and functionality of our website. If you have questions or comments about your privacy rights, you may email us at getchopsquad@gmail.com

10. Security

ChopSquad has established and maintains security measures to ensure the confidentiality, integrity, and security of your User account and Personal Data. These measures are designed to prevent unauthorized access, disclosure, modification,alteration, damage, accidental loss, accidental or unlawful destruction, andany other unauthorized processing or disclosure.

To enhance your security, we strongly advise following best practices, such assecurely storing your account information and refraining from sharing it withothers.

We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers or cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

11. Updates on Privacy Policy

We may update this notice as necessary to stay compliant with relevant laws from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice ofsuch changes or by directly sending you a notification. We encourage you toreview this privacy notice frequently to be informed of how we are protecting your information

12. Jurisdiction andAcceptable Law

This privacy notice is made pursuant to the Nigerian Data Protection Regulation(2019) and any other relevant Nigerian laws, regulations, or international conventions applicable to Nigeria. Where any provision of this policy is deemed inconsistent with a law, regulation, or convention, such provision shall be subject to overriding law, regulation, or convention

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacypractices, please contact us at: If you have questions or comments about this notice, you may email us at getchopsquad@gmail.com or by post to: 

NAEMO GLOBAL LIMITED.
HOUSE 5, PUNCH ESTATEMANGORO, LAGOS STATE
100283, NIGERIA