Privacy Policy

1. Data Controller

The data controller responsible for processing your personal information is:

S Ludens FZCO
A Free Zone Company registered in Dubai Multi Commodities Centre (DMCC), United Arab Emirates
License number: DMCC195008

Contact email: support@usemytrack.com

2. Information We Collect

We collect the following categories of personal information:

2.1. Information You Provide Directly

When you register and use the Service, we may collect:

• Account information: email address, username, password (hashed), profile picture
• Identity information: name, date of birth, country of residence (where applicable)
• Contact information: phone number, messaging app contacts (Telegram username)
• Payment information: cryptocurrency wallet addresses, payment service identifiers (such as Pix keys for Brazilian users, where applicable)
• Tax identification: CPF (for Brazilian users using Pix), other tax IDs where required by law
• Communication content: messages you send to our support team

2.2. Information Collected Automatically

When you use the Service, we automatically collect:

• Device information: device type, operating system, browser type, unique device identifiers
• Log data: IP address, access times, pages viewed, actions taken on the Platform
• Usage data: tasks completed, rewards earned, time spent on the Platform, in-app interactions
• Location data: approximate location based on IP address (city/country level)
• Cookies and similar technologies: see Section 9 for details

2.3. Information from Third Parties

We may receive information about you from:

• Third-party platforms: when you authorize the Service to access your accounts on Spotify, TikTok, Instagram, YouTube, or other supported platforms for task verification purposes
• Payment processors: confirmation of successful payments and basic transaction details
• Authentication providers: when you log in using third-party authentication (such as Telegram)

3. How We Use Your Information

We use your personal information for the following purposes:

3.1. Providing the Service

• Creating and maintaining your account
• Processing tasks you complete
• Calculating and crediting rewards
• Processing withdrawal requests
• Verifying task completion authenticity
• Providing customer support

3.2. Communication

• Sending service-related notifications (task availability, reward credits, withdrawal status)
• Responding to your inquiries and support requests
• Sending important updates about the Service or these Terms
• Marketing communications (only with your consent, where required)

3.3. Improvement and Analytics

• Analyzing usage patterns to improve the Platform
• Developing new features
• Conducting research and analytics on aggregated, anonymized data

3.4. Security and Compliance

• Preventing fraud and abuse
• Detecting bot activity and inauthentic behavior
• Complying with legal obligations, including AML/CTF requirements
• Enforcing our Terms of Use

3.5. Legal Bases (for Users in the EU/UK)

We process your personal data on the following legal bases under GDPR:

• Contract performance: to provide the Service you have agreed to use
• Legitimate interests: to improve our Service, prevent fraud, and ensure security
• Legal obligation: to comply with applicable laws and regulations
• Consent: where specifically required (such as marketing communications)

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

4.1. Service Providers

We share information with third-party service providers who help us operate the Platform, including:

• Payment processors (for withdrawals): cryptocurrency payment infrastructure providers, Pix payment service providers (for Brazilian users)
• Cloud hosting providers: for storing data and operating our infrastructure
• Analytics providers: for understanding Platform usage (in aggregated form where possible)
• Customer support tools: for managing user inquiries
• Email and messaging services: for sending notifications

These service providers are contractually bound to use your information only for the purposes we specify.

4.2. Third-Party Platforms

When you authorize the Service to access your accounts on streaming platforms (Spotify) or social media (TikTok, Instagram, YouTube) for task verification, those platforms may receive limited information about your activity.

4.3. Promoted Artists

When you complete promotional tasks, anonymous or aggregated information about task completion may be shared with the artists whose music was promoted (for example, total number of streams or shares). We do not share your personal identity with artists unless specifically required for a verifiable task.

4.4. Legal Requirements

We may disclose your information when required by law, including:

• Responding to lawful requests from public authorities
• Complying with court orders or subpoenas
• Reporting suspicious transactions under AML regulations
• Protecting our rights and the safety of users

4.5. Business Transfers

In the event of a merger, acquisition, or sale of all or part of our business, your information may be transferred to the acquiring entity, subject to appropriate confidentiality obligations.

5. International Data Transfers

The Service operates globally, and your information may be transferred to and processed in countries other than your country of residence, including the United Arab Emirates, where our data controller is located.

For users in the European Union/EEA, when we transfer data outside the EEA, we ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions where available
• Other legally recognized transfer mechanisms

For users in Brazil, we comply with LGPD requirements for international data transfers, including adequacy assessments and appropriate safeguards.

6. Data Retention

We retain your personal information for as long as necessary to:

• Provide you with the Service
• Comply with our legal obligations (typically 5-7 years for financial and tax records)
• Resolve disputes
• Enforce our agreements

When your account is closed, we will delete or anonymize your personal information within a reasonable timeframe, except where retention is required by law or legitimate business purposes.

7. Your Rights

Depending on your country of residence, you may have the following rights regarding your personal information:

7.1. Rights Under GDPR (EU/UK Users)

• Right of access: to know what personal information we hold about you
• Right to rectification: to correct inaccurate information
• Right to erasure (“right to be forgotten”): to request deletion of your data
• Right to restriction of processing: to limit how we use your data
• Right to data portability: to receive your data in a structured format
• Right to object: to object to certain types of processing
• Right to withdraw consent: where processing is based on consent
• Right to lodge a complaint: with your local data protection authority

7.2. Rights Under LGPD (Brazilian Users)

Similar rights are provided under Brazil's General Data Protection Law, including access, correction, deletion, portability, and the right to be informed about data sharing.

7.3. Rights Under UAE PDPL

Users in the UAE have rights to access, correct, delete, and object to the processing of their personal data under the UAE Personal Data Protection Law.

7.4. How to Exercise Your Rights

To exercise any of these rights, please contact us at: support@usemytrack.com

We will respond to your request within the timeframes required by applicable law (typically 30 days under GDPR and LGPD).

8. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit (HTTPS/TLS)
• Encryption of sensitive data at rest
• Access controls and authentication
• Regular security audits
• Staff training on data protection

However, no method of transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

9. Cookies and Similar Technologies

The Service uses cookies and similar tracking technologies to:

• Maintain your login session
• Remember your preferences
• Analyze how the Service is used
• Prevent fraud

You can control cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the Service.

For more detailed information about cookies we use, please refer to our Cookie Policy (where applicable).

10. Children's Privacy

The Service is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected information from a child under 18, we will delete it promptly.

11. Third-Party Links and Services

The Service may contain links to third-party websites or integrate with third-party services (such as Spotify, TikTok, payment processors). This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party services you use.

12. Marketing Communications

If you have opted in to receive marketing communications, you can unsubscribe at any time by:

• Clicking the unsubscribe link in any marketing email
• Updating your preferences in your account settings
• Contacting us at support@usemytrack.com

Service-related notifications (such as withdrawal confirmations) are not considered marketing and will continue regardless of your marketing preferences.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When material changes are made:

• We will update the “Last updated” date at the top of this Policy
• We will notify users via email or platform notification at least 30 days before changes take effect (where required by law)

Continued use of the Service after changes take effect constitutes acceptance of the updated Policy.

14. Data Protection Officer

For questions or concerns about your privacy or this Policy, you can contact our Data Protection Officer at: support@usemytrack.com

For users in the EU, you also have the right to lodge a complaint with your local Data Protection Authority.

15. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact:

S Ludens FZCO
Email: support@usemytrack.com
Address: Dubai Multi Commodities Centre, Dubai, United Arab Emirates