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PRIVACY POLICY – XSPORTY

Effective Date: July 19, 2025

This Privacy Policy governs the collection, use, processing, storage, and protection of personal and other data ("Data") by XSPORTY LLC, located in San Juan, Puerto Rico. Contact: admin@xsporty.com

1. Definitions

Personal Data: Information identifying a natural person. Processing: Any operation on Data (automated or manual). Platform: XSPORTY mobile app, website, APIs, push notifications, and other digital tools.

2. Data We Collect

Account Data: First/last name, username, profile photo, hashed password Contact Data: Email, phone number Sports Profile (optional): Sport, skill level, position, physical data Location Data: Real-time geolocation (with user consent), venue locations User-Generated Content: Messages, photos, videos, match ratings, comments Technical Data: Device IDs, IP address, OS, cookies, web beacons Payment Data: Tokenized via secure third-party provider (no full card storage)

3. Purposes and Legal Bases

Your data is used to: • Register and manage your account • Enable game discovery and coordination • Send necessary communications • Prevent fraud and ensure security • Conduct analytics and improve the Platform • Comply with legal requirements • Send marketing emails (with consent)

4. Moderation & Reports

Abuse reports are encrypted and reviewed within 24 hours. Action may include content removal or account suspension. Evidence is retained up to 12 months, then deleted or anonymized.

5. User Rights

Email admin@xsporty.com to: • Access, update, or delete your data • Request portability or processing restrictions • Appeal moderation decisions We respond within 72 hours.

6. Security

We follow industry standards including: • TLS 1.3 and AES-256 encryption • Bcrypt password hashing • Daily backups and testing • Third-party penetration tests and audits

7. Data Retention & Deletion

User deletion: Immediate upon in-app confirmation Zero-tolerance cases: Retain only necessary evidence (12 months) Inactive accounts: Deleted after 24 months of inactivity

8. Breach Notification

Users and the Puerto Rico Department of Justice will be notified of breaches within 10 days.

9. International Transfers

We use SCCs or the Data Privacy Framework for transfers outside the EEA/UK.

10. Third-Party Links

We are not responsible for the data practices of third-party websites or apps. Please review their privacy policies.

11. Policy Changes

We may update this Policy to reflect legal or operational changes. We'll notify users at least 10 days in advance via email or app notifications.

12. Contact

For privacy or abuse inquiries: admin@xsporty.com

13. Acceptance

By using the Platform, you agree to this Privacy Policy and authorize processing of your Data.

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