Date: January 29, 2025
Version 1.0

Introduction

We are NextGen Development Labs Ltd., a company incorporated under the laws of Republic of Seychelles, residing at the Office 14, First Floor, Trinity House, Victoria, Mahé, Seychelles (hereinafter “We”, “Company”, “Us”).

This Privacy Policy clearly outlines how and what data is collected by the Platform and our Services, as well as the purposes for which we collect such data and how we subsequently use it.

1win Token is the mini app hosted on Telegram and that can be accessed via the following link: https://t.me/token_1win (hereinafter referred to as the "Platform").

The Company is the controller, processor of the Platform and responsible for your personal data. Being the controller, the Company independently determines the personal data processing purposes and means. This Policy is drafted in accordance with the laws of Seychelles, provisions of GDPR Regulation - Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation), as well as other applicable laws and regulations.

0. DEFINITIONS

0.1. User – the person using the Platform (also “You”, “Your”).

0.2. Policy – this document, governing the relationship between Us and User.

0.3. Services – our products and other services offered by us and our affiliates via Platform.

Your continued access to and use the Platform shall constitute your acceptance of the Policy. If you do not accept all the aforementioned terms, you should immediately cease your use of the Platform.

1. DATA WE COLLECT

A. Data that You provide to Us yourself

By using our Platform, You grant us access to certain personal data, including your first name, last name, Telegram ID, username (alias), avatar, and language preference. This information is necessary for us to provide the services of the Platform.

Without limiting section A, the Platform has the ability to receive additional data from You if you send it messages, upload files to it, or choose to share personal information such as your contact or phone number.

B. Information We Collect Automatically

In addition to the information specified in Section A, We automatically collect certain data through cookies, including but not limited to your IP address, operating system, geographic location, and browsing activity on the Platform.

C. Information We Collect from Other Sources

In some cases, we may also receive information about you from service providers and third parties in connection with your use of the Services or your interactions with us on other platforms.

Moreover, the Platform may collect anonymous data that is not linked to you in any way, such as anonymized diagnostics or usage statistics.

2. THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

In processing your personal data, we rely on one of the legal grounds outlined below. The specific grounds may vary depending on the context of data collection. However, we assure you that the collection and processing of your data are exclusively based on the legal grounds specified herein.

2.1. Provision of Services: We use Your data for the direct purpose of earning digital tokens on our service.

2.2. Legitimate Interests: We process your data in our legitimate interests, including but not limited to the efficient management of our business, monitoring and improving our Platform and services, and protecting and enforcing our legal rights.

2.3. Security and Issue Resolution: We may process your data to detect and address security issues related to the provision of our services, unless such interests are outweighed by your rights and freedoms that require the protection of personal data.

2.4. Consent: In limited circumstances, we may process your data based on your explicit consent.

3. TERM OF THE PROCESSING YOUR DATA

3.1. We process your data for as long as our processing purposes, the legal retention periods, and our legitimate interests require it, or storage is a technical necessity. If there are no contrary legal or contractual obligations, we will delete or anonymize your data once the storage or processing period has expired.

EXCEPTION: Please, note that We have right to continue to retain some of your user data even after complying with your request to delete such data in the following cases:

(A) Such copies of the information may be required to safeguard the legitimate interests of us or third parties, to comply with governmental or regulatory orders, to resolve disputes, address technical issues, or to ensure the enforcement of any agreement you have entered into with us. This includes, but is not limited to, cases where it is necessary to investigate potential breaches of contract, address issues related to service delivery, protect against fraud, or cooperate with legal authorities as part of compliance with applicable laws and regulations.

(B) Your user data has been anonymized in such a way that it can no longer be used to identify you directly or indirectly. As a result, this information is no longer considered personal data under applicable privacy laws, as it has been stripped of all identifiers that could be traced back to you. This anonymization process ensures that the data cannot be linked to any individual, thereby removing any privacy concerns regarding its use.

4. SHARING INFORMATION

We reserve the right to share your data in the following circumstances:

A) When such data is aggregated or anonymized in a way that makes it impossible to identify you personally;

B) To protect the operation of the Platform;

C) We may share your data with our business partners involved in the Platform's operation. For instance, we engage authorized payment service providers to process payments for our Services. Depending on your region, your data may be shared with payment service providers licensed to operate in that region or country, as well as with advertising partners who assist us with tracking and analytical tools. Additionally, we may share your data with third-party service providers who help us deliver our Platform, including those providing operational and technological services;

D) To comply with a legal obligation (if required by applicable law), protect and defend our rights or property, prevent or investigate potential misconduct related to the Service, and defend against legal claims;

E) Due to selling or reorganizing all or parts of our business;

F) To protect the personal safety of other Platform Users or the public.

5. TRANSFERRING YOUR DATA ABROAD

5.1. The Company and service providers may transfer your personal data to jurisdictions with different levels of data protection. We take necessary steps, as required by applicable law, to ensure adequate protection in each case. Some countries may not have the same data protection standards as your jurisdiction.

5.2. If you are in the EEA, the Company ensures adequate protection for data transfers outside the EEA through intercompany agreements based on Standard Contractual Clauses in accordance with Article 46 of the GDPR.

6. HOW DO WE USE INFORMATION?

In general, the data we collect (either individually or combined with other information as outlined in this policy) is utilized to facilitate the provision, enhancement, and customization of our Services, as well as for analysis and promotion in accordance with our Terms and Conditions. The purposes for which we use the collected information are as follows:

Purpose	Meaning
Provision and Support of Services	We utilize the information to effectively deliver the Services, provide necessary support, respond to user inquiries, process service requests, and maintain communication with users through service-related notifications and updates.
Marketing, Advertising, and Promotion	We use the information to manage, optimize, and evaluate the effectiveness of our advertising campaigns, promotional activities, and events. This includes custom-tailoring advertisements and offers to enhance your experience and engagement with our Services.
Improvement and Development of Services	The data is employed to enhance the functionality, quality, and scope of our Services. This includes improving existing features and introducing new offerings that better meet your evolving needs and preferences.
Personalization of User Experience	We leverage the collected data to tailor and personalize your interaction with our Services, providing content, recommendations, and features that align with your individual interests, preferences, and behaviors, as well as our insights regarding your usage patterns.
User Feedback and Continuous Improvement	Feedback collected from users is used to identify opportunities for further enhancement of the Services. This allows us to continuously refine the user experience, address potential issues, and improve overall service quality.
Data Analytics and Insights	We analyze user data to gain insights into how our Services are being used. This analysis enables us to improve service delivery, identify trends, and further refine the Services to better suit user needs and preferences.
Compliance with Legal Obligations and Enforcement	We may use the collected data to ensure compliance with applicable legal, regulatory, and contractual requirements. This includes enforcing the Terms and Conditions of the Services, resolving disputes, and protecting our legal rights as well as the rights of our users.
User Feedback and Continuous Improvement	Feedback collected from users is used to identify opportunities for further enhancement of the Services. This allows us to continuously refine the user experience, address potential issues, and improve overall service quality.
Security, Risk Management, and Fraud Prevention	The data is also utilized to safeguard the security and integrity of our Services. This includes monitoring for any potential security breaches, detecting and preventing fraudulent activities, and ensuring a safe and secure environment for all Users.

7. COOKIES

Our Platform and Services use cookies to enhance your experience and distinguish you from other users. The types of cookies we use are:

(a) Necessary cookies: Essential for the proper functioning of our Platform, such as enabling secure logins.

(b) Security cookies: Improve the security of our Platform to ensure safe access.

(d) Functionality cookies: Remember your preferences to personalize Your experience when you return.

8. SECURITY OF DATA

8.1. We prioritize the security of your data, but please note that no transmission method or electronic storage is 100% secure. While we use commercially reasonable measures to protect your Personal Data, we cannot guarantee its absolute security. You are responsible for keeping your login credentials confidential to protect your information.

8.2. We implement appropriate safeguards to protect your personal data from unauthorized access, loss, or misuse.

8.3. If we become aware of any unauthorized disclosure of your personal information, we will notify you as required by law and take steps to secure your data.

9. YOUR RIGHTS

You possess the following rights with respect to your personal data, which are designed to ensure transparency and control over how your data is processed:

Right	Meaning
Right to Access	You have the right to request information regarding the personal data we hold about you, including details on the purposes of processing, the categories of data concerned, and the recipients of such data. You may request access to the specific data we process, and we will provide a copy of it, subject to any applicable legal exceptions.
Right to Restrict Processing	In certain circumstances, you may request that we limit the processing of your personal data. This includes cases where you contest the accuracy of the data, where processing is unlawful but you request restriction instead of erasure, or where you have objected to the processing and we are considering whether our legitimate grounds for processing override your rights.
Right to Erasure	You may request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, or when you withdraw consent that was the basis for its processing. Additionally, this right may be exercised in cases where the data has been unlawfully processed, or if it must be erased to comply with a legal obligation.
Right to Rectification	You are entitled to request the correction of any inaccurate, incomplete, or outdated personal data that we hold about you. If the data is found to be incorrect, we will take all reasonable steps to ensure that the information is updated or corrected accordingly.
Right to Object	You have the right to object to the processing of your personal data in certain circumstances, particularly when the processing is based on our legitimate interests, or when the data is processed for direct marketing purposes. We will carefully assess your objection and cease processing unless we can demonstrate compelling legitimate grounds for continuing.
Right to Data Portability	You have the right to request that we provide your personal data in a structured, commonly used, and machine-readable format, or to have that data transferred directly to another organization, where technically feasible. This right applies to data that you have provided to us, where the processing is based on consent or a contract, and is carried out by automated means.
Right to Lodge a Complaint	If you believe that we have infringed your rights, you have the right to complain to the local Data Protection Authority. However, we highly recommend you to contact us first to seek a resolution.

9.2. How to exercise your rights?

If you want to exercise any of these rights with respect to the Company processing your personal data, please submit your request to the Company according to the section 11 of the Privacy.

10. CHANGES TO THIS PRIVACY POLICY

10.1. We reserve the right to modify or update the terms of this Policy at our discretion and as we deem necessary. Any changes to this Policy will be effective immediately upon posting the updated version on our Platform, unless otherwise stated. It is your responsibility to review this Policy periodically to stay informed about how We are protecting your personal data.

10.2. If you do not agree with the updated Policy, You may choose to discontinue using our Services.

11. CONTACT US

If You have any questions or concerns regarding this Privacy Policy, please do not hesitate to contact our support team at official@1wintoken.com. Alternatively, You may submit Your inquiry or request in writing to our registered address. To ensure that we address Your inquiry promptly and accurately, we kindly ask that you reference this Privacy Policy in Your communication.

We are committed to responding to Your request as quickly as possible. Our standard response time is within 15 days of receipt of your inquiry, or within any shorter time frame mandated by applicable law. Please be advised that in certain circumstances, the complexity of your request may result in a longer response time, in which case We will notify You promptly and keep you informed of the status of your inquiry.