1. Introduction
This Privacy Policy (“Policy”) explains how LasMeta Platform (“Company,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal data when you use the LasMeta web poker client and related sites (“Platform”). Access is primarily through modern desktop and mobile browsers; you may also launch the experience inside supported Farcaster mini apps or Startale-enabled wallet surfaces.
Wallet connections (EOAs and smart accounts), chain interactions on Soneium (chain id 1868), and third-party SDKs such as WalletConnect may generate additional technical identifiers. See also our wallet disclosures and cookie policy.
By accessing or using the Platform, you consent to the collection, use, and disclosure of your personal data in accordance with this Policy. If you do not agree, you must not access or use the Platform.
2. Data Controller and Data Processor
LasMeta Platform acts as the Data Controller with respect to your personal data as defined under the General Data Protection Regulation (EU) 2016/679 (“GDPR”). We may also act as a Data Processor when processing data on behalf of third parties in accordance with applicable data protection laws.
3. Personal Data We Collect
3.1 Types of Data Collected
We collect various types of personal data from you, including but not limited to:
- • Identification Data: Full name, date of birth, nationality, and other identifying information.
- • Contact Information: Email address, phone number, and mailing address.
- • Blockchain Information: Wallet addresses, chain id (Soneium 1868), transaction hashes, gas usage, and contract event data tied to buy-ins, cash-outs, approvals, or cosmetics.
- • KYC Data: Identity verification documents (e.g., passport, driver's license) and other information necessary for Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance.
- • Technical Data: IP address, device information, browser type, operating system, and other technology on the devices you use to access the Platform.
- • Usage Data: Information about how you use our Platform, including in-game activities, interactions, and communication logs.
- • Profile Data: Username, preferences, and other profile information.
- • AI Interaction Data: Data related to AI coaching and personalized gaming experiences.
3.2 Sensitive Personal Data
We may collect sensitive personal data only where it is necessary and with your explicit consent or as otherwise permitted by law. This includes data such as precise geolocation, account credentials, and any communication content where you use chat features within the Platform.
4. Legal Basis for Processing Personal Data
We process your personal data based on one or more of the following legal grounds:
- • Performance of a Contract: Processing necessary for the performance of a contract to which you are a party, such as providing the Platform and related services.
- • Legal Obligation: Processing necessary to comply with legal obligations, including those related to AML/KYC regulations and gaming compliance.
- • Legitimate Interests: Processing necessary for our legitimate interests, such as improving our services, ensuring the security of the Platform, and conducting marketing activities, provided that your interests and fundamental rights do not override those interests.
- • Consent: Processing based on your explicit consent, which you can withdraw at any time as detailed in this Policy.
5. How We Use Your Personal Data
We use your personal data for the following purposes:
- • Provision of Services: To operate tables, matchmaking, chat moderation, wallet login, on-chain settlement where enabled, and customer support.
- • Compliance: To comply with legal obligations, including KYC/AML requirements, and to prevent fraud, money laundering, and other illegal activities.
- • Platform Security: To maintain the security and integrity of our Platform, including the use of Pyth Entropy for provably fair gaming and on-chain verification.
- • AI Enhancement: To provide AI-driven coaching, dynamic difficulty adjustment, and personalized gaming experiences.
- • Communication: To send you service-related communications, such as updates, security alerts, and account notifications.
- • Marketing and Promotions: To send you promotional materials, subject to your preferences, and to personalize your experience based on your usage data.
- • Analysis and Improvements: To analyze usage data to understand how our Platform is used and to improve its performance and user experience.
6. Data Sharing and Disclosure
We do not sell or trade your personal data. However, we may share your data in the following circumstances:
- • Service Providers: With third-party service providers who perform services on our behalf, such as payment processing, identity verification, data analytics, and IT services, under strict confidentiality obligations.
- • Legal and Regulatory Authorities: When required by law or to comply with legal processes, such as a court order, subpoena, or regulatory request.
- • Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction, subject to the continuation of data protection obligations.
- • Protection of Rights: Where necessary to protect our rights, property, or safety, or that of our users, employees, or others.
- • Blockchain Transparency: Certain transaction data may be visible on the blockchain as required for transparency and verification purposes.
7. International Data Transfers
Your personal data may be transferred to, and processed in, countries outside the European Economic Area (EEA) that may have different data protection laws. We ensure that such transfers are made in compliance with applicable laws and that appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission, are in place to protect your data.
8. Data Security
We have implemented industry-standard security measures to protect your personal data from unauthorized access, use, or disclosure. These measures include encryption, secure storage, access controls, and blockchain security protocols. However, no data transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.
9. Data Retention
We will retain your personal data only as long as necessary to fulfill the purposes outlined in this Policy or as required by law. After this period, your data will be securely deleted or anonymized. Blockchain transaction data may be retained indefinitely as required by blockchain immutability.
10. Your Data Protection Rights
Under applicable data protection laws, including the GDPR, you have the following rights regarding your personal data:
- • Right to Access: The right to request access to your personal data and obtain a copy of the data we hold about you.
- • Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
- • Right to Erasure: The right to request the deletion of your personal data under certain conditions.
- • Right to Restrict Processing: The right to request the restriction of processing your personal data under certain circumstances.
- • Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller.
- • Right to Object: The right to object to the processing of your personal data for specific purposes, including direct marketing.
- • Right to Withdraw Consent: Where processing is based on consent, the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
To exercise any of these rights, please contact us at [email protected]. We will respond to your request within the legally required timeframes.
11. Use of Cookies and Similar Technologies
We use cookies and similar tracking technologies to enhance your experience on our Platform, analyze trends, and gather demographic information. You can manage your cookie preferences through your browser settings or by using our Cookie Policy.
12. AI and Machine Learning
Our Platform uses artificial intelligence and machine learning technologies to provide personalized gaming experiences, coaching, and difficulty adjustment. This processing is based on our legitimate interests in improving user experience and is conducted in accordance with applicable data protection laws.
13. Blockchain and on-chain data
LasMeta may anchor economically meaningful actions to Soneium. Wallet addresses, amounts, and calldata can be permanent on-chain. We minimise personal data in transactions, but you should assume signing is public to chain observers. Startale or other relays may temporarily process user operations under their own infrastructure policies.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. We will notify you of any significant changes by posting the updated Policy on our Platform, and where required, by providing direct notification. Your continued use of the Platform following the posting of changes constitutes your acceptance of such changes.
15. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:
LasMeta Platform
Global Operations
