PRIVACY POLICY

1. INTRODUCTION

Welcome to Zoloto Nexus. This Privacy Policy describes how Zoloto Systems ("we," "us," "our," "the Company") collects, uses, discloses, and protects your personal information when you access or use our software, website, and related services (collectively, "the Service").

By using Zoloto Nexus, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with this policy, please discontinue use of the Service immediately.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

When you register, subscribe, or contact us, we may collect:

• Account Information: Username, email address, password (encrypted)
• Payment Information: Cryptocurrency wallet addresses, transaction IDs (processed securely via Coinbase Commerce - we do NOT store credit card or banking information)
• Support Communications: Messages sent through support tickets or email
• Profile Data: Optional settings, preferences, and customization choices

2.2 Information Collected Automatically

When you use our Service, we automatically collect:

2.3 Information from Third Parties

We may receive information from:

• Payment Processors: Transaction confirmation, payment status
• Analytics Providers: Aggregated usage statistics (e.g., Google Analytics)
• Fraud Prevention Services: Risk scores, device fingerprints

2.4 THE HIGH TABLE (Invite-Only Module)

If you access THE HIGH TABLE (invite-only), we may collect limited information you submit for planning/coordination purposes, such as:

• Alias / Display Name: A name you choose to appear to invited members
• Contact Method: Email/Discord/other contact you provide for coordination
• Preferences / Intent: Non-financial preferences or intake details you submit (including whether you prefer equal-seat vs weighted-seat contributions)
• Estimated Contribution (Optional): If you choose to provide it for weighted-seat planning
• Pool Accounting Entries (If Enabled): Contribution amounts you enter, allocation mode, and related bookkeeping metadata
• Profit Periods / Session Snapshots (If Enabled): Period windows, labels, and optional session records used for operational reporting
• Payout Bookkeeping (If Enabled): Your computed profit share for a period and payout-status fields used for recordkeeping (not a payment processor)
• Invite, Application & Membership Metadata: Invite redemption status, application state, and access-control signals
• Cycle / Seat / Waitlist Metadata: Limited operational metadata such as cycle timing, seat status (e.g., reserved/active), and waitlist position/status
• Seat Fee Payment References: Payment IDs/charge IDs and confirmation status from our payment processor (we do not store card or bank data)

Important: THE HIGH TABLE is an invite-only module. We do not custody user funds or provide escrow. Any pooled bankroll arrangement between participants (if any) occurs off-platform. If enabled, we may store internal accounting and payout-status bookkeeping to help invited members coordinate, and we may process a separate seat fee for platform access through Coinbase Commerce.

Visibility note: If pool accounting or payout bookkeeping is enabled, invited members may be able to view contribution amounts, computed weights, and payout-status indicators (e.g., paid/pending) for other invited members within THE HIGH TABLE. Payout-status indicators are controlled by administrators and are for recordkeeping only (not a payment processor confirmation).

3. HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

3.1 Service Delivery

• Providing access to the Zoloto Nexus software
• Authenticating your identity and managing your account
• Processing subscription payments and renewals
• Delivering customer support and responding to inquiries

3.2 Security & Fraud Prevention

• Detecting and preventing unauthorized access
• Enforcing license agreements and terms of service
• Monitoring for suspicious activity or violations
• Hardware ID (HWID) binding to prevent account sharing

3.3 Service Improvement

• Analyzing usage patterns to optimize performance
• Identifying bugs, errors, and technical issues
• Developing new features and enhancements
• Conducting A/B testing and user experience research

3.4 Communication

• Sending transactional emails (e.g., purchase confirmations, password resets)
• Providing service updates, security alerts, and important notices
• Sending marketing communications (with your consent, where required)

3.5 Legal Compliance

• Complying with applicable laws and regulations
• Responding to legal requests (subpoenas, court orders)
• Protecting our rights, property, and safety

3.6 Alpha50 & Golden Ticket Programs

If you participate in Alpha50 or receive/attempt to redeem a Golden Ticket, we may use your information to:

• Create, hold, and release limited-access reservations ("reserved" status) and prevent seat hoarding
• Verify eligibility, enforce redemption limits, and detect fraud or multi-account abuse
• Confirm payment status and activate entitlements after successful confirmation
• Provide program communications (e.g., activation notices, expiration warnings, or support messages)

3.7 THE HIGH TABLE (Invite-Only Module)

If you access THE HIGH TABLE, we may use your information to:

• Verify invite redemption and enforce invite-only access
• Store and display your submitted intake fields to authorized users (including roster display, where applicable)
• Operate monthly cycles, manage seat availability, and administer waitlists
• Confirm seat fee payment status via Coinbase Commerce and activate access after confirmation
• Prevent abuse, spam, fraud, or harassment within the module
• Respond to High Table support requests and moderation/enforcement actions

4. DATA SHARING & DISCLOSURE

4.1 Service Providers

We share data with trusted third-party vendors who help us operate the Service:

• Payment Processors: Coinbase Commerce (for cryptocurrency payment processing - a trusted, enterprise-grade gateway used by thousands of businesses worldwide)
• Hosting Providers: AWS, Google Cloud (for data storage and infrastructure)
• Analytics Tools: Google Analytics (for usage insights)
• Email Services: SendGrid, Mailchimp (for transactional and marketing emails)

These providers are contractually obligated to protect your data and use it only for specified purposes.

4.2 Legal Requirements

We may disclose your information if required by law or in response to:

• Subpoenas, court orders, or legal processes
• Requests from law enforcement or government agencies
• Protection of our legal rights or defense against claims
• Prevention of fraud, abuse, or illegal activity

4.3 Business Transfers

If Zoloto Systems is acquired, merged, or undergoes a business restructuring, your information may be transferred to the acquiring entity as part of the transaction.

4.4 With Your Consent

We may share your information with third parties if you explicitly consent (e.g., opting into partner promotions).

4.5 THE HIGH TABLE Roster (Invite-Only Disclosure)

If you participate in THE HIGH TABLE, certain submitted fields may be visible to other invited members in a roster view. This may include your alias/display name, preferences related to equal-seat vs weighted-seat contributions, and any optional intake details you submit.

If pool accounting is enabled, invited members may also be able to view contribution amounts, computed weights, and informational profit-share outputs within the High Table module. Payout-status bookkeeping (paid/unpaid) is intended for administrative recordkeeping and may be visible to administrators and to you for your own entries.

The roster is designed to display masked contact rather than full contact details; however, you acknowledge that any disclosure to other users carries inherent privacy risks.

5. DATA SECURITY

We implement industry-standard security measures to protect your information:

5.1 Technical Safeguards

• Encryption: All data transmitted between your device and our servers is encrypted using TLS/SSL
• Password Protection: Passwords are hashed using bcrypt or equivalent algorithms
• Secure Servers: Data is stored on secure, access-controlled servers
• Firewall Protection: Network-level security to prevent unauthorized access

5.2 Organizational Safeguards

• Access to personal data is restricted to authorized personnel only
• Employees are trained on data privacy and security best practices
• Regular security audits and vulnerability assessments

5.3 Limitations

While we take reasonable precautions, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

5B. ALPHA50 & GOLDEN TICKET DATA

What We May Store

• Reservation Metadata: Reservation status (e.g., reserved/claimed/expired), timestamps, and expiration windows
• Redemption Metadata: Redemption attempts, eligibility checks, and anti-abuse signals
• Identity Signals: Account ID, masked email/username, and device integrity signals (e.g., HWID) for fraud prevention
• Payment References: Payment IDs/charge IDs and confirmation status (we do not store card or bank data)

How We Use It

• To prevent duplicate redemptions, botting, and multi-account manipulation
• To protect inventory limits (e.g., seat count) and keep the program operational for real users
• To investigate disputes, support requests, and security incidents

How Long We Keep It

Program reservation and redemption metadata may be retained for a limited period to prevent abuse and support audits. Where feasible, expired reservation holds may be deleted or anonymized on a rolling basis.

5A. PAYMENT SECURITY & CRYPTOCURRENCY

Why Coinbase Commerce?

We exclusively use cryptocurrency payments via Coinbase Commerce to provide you with:

• Enhanced Privacy: No sensitive financial data (credit cards, bank accounts) is ever shared with us
• Superior Security: Blockchain-based transactions eliminate chargeback fraud and payment disputes
• Global Accessibility: Accept payments from anywhere in the world without banking restrictions
• Lower Fees: Cryptocurrency transactions have significantly lower processing fees than traditional payment methods
• Instant Settlement: Faster transaction confirmation compared to credit card processing

What We Collect from Coinbase Commerce

When you make a payment, we receive only:

• Transaction confirmation status (completed/pending/failed)
• Public cryptocurrency wallet address (if provided)
• Transaction ID (for verification and support purposes)
• Payment amount and timestamp

We do NOT receive:

• ❌ Credit or debit card numbers
• ❌ Bank account details
• ❌ CVV/security codes
• ❌ Billing addresses (unless voluntarily provided for invoicing)
• ❌ Your private cryptocurrency keys

Coinbase Commerce Security Standards

Coinbase Commerce is a trusted payment gateway used by thousands of businesses worldwide, including:

• PCI DSS Compliance: Meets Payment Card Industry Data Security Standards
• SOC 2 Type II Certified: Audited for security, availability, and confidentiality
• Cold Storage: 98% of cryptocurrency assets stored offline for maximum security
• Insurance Coverage: Digital asset insurance for platform security breaches
• Regulatory Compliance: Licensed and regulated in multiple jurisdictions

Supported Cryptocurrencies

We accept payments in the following cryptocurrencies via Coinbase Commerce:

Transaction Transparency

All cryptocurrency transactions are:

• Publicly verifiable on the blockchain (transaction IDs can be viewed on block explorers)
• Immutable - once confirmed, transactions cannot be reversed or altered
• Pseudonymous - wallet addresses are not directly linked to personal identities

Refunds & Disputes

Due to the irreversible nature of cryptocurrency transactions:

• No chargebacks: Unlike credit cards, crypto payments cannot be disputed or reversed
• Refund policy: We do not offer refunds (see Terms of Service). All subscriptions include a 48-hour trial period
• Manual refunds: In exceptional cases, refunds must be manually processed to your original wallet address

6. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

6.1 Retention Periods

• Account Data: Retained while your account is active, plus 90 days after account closure
• Payment Records: Retained for 7 years (for tax and legal compliance)
• Usage Logs: Retained for 90 days (for analytics and troubleshooting)
• Support Communications: Retained for 2 years (for quality assurance)
• High Table Submissions: Retained while you have access to THE HIGH TABLE and for a limited period after access is revoked or upon deletion request, subject to legal and security requirements

6.2 Deletion

After the retention period expires, we securely delete or anonymize your data. You may request early deletion by contacting us (see Section 9).

7. YOUR RIGHTS & CHOICES

Depending on your location, you may have the following rights:

7.1 Access & Portability

• Right to Access: Request a copy of the personal data we hold about you
• Right to Portability: Receive your data in a machine-readable format

7.2 Correction & Deletion

• Right to Correction: Update inaccurate or incomplete information
• Right to Deletion: Request deletion of your personal data (subject to legal obligations)

7.3 Objection & Restriction

• Right to Object: Object to processing of your data for marketing purposes
• Right to Restriction: Request limitation of processing under certain circumstances

7.4 Marketing Opt-Out

You can unsubscribe from marketing emails by clicking the "Unsubscribe" link in any promotional email or by contacting us.

7.5 Cookie Controls

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

8. CHILDREN'S PRIVACY

Zoloto Nexus is not intended for individuals under the age of 18 (or the legal gambling age in your jurisdiction). We do not knowingly collect personal information from children.

If we discover that a child has provided us with personal information, we will promptly delete it. If you believe a child has provided us with information, please contact us immediately.

9. INTERNATIONAL DATA TRANSFERS

Zoloto Systems operates globally. Your information may be transferred to, stored, and processed in countries other than your country of residence, including the United States.

These countries may have different data protection laws than your jurisdiction. By using our Service, you consent to the transfer of your information to these locations.

For EU/UK Users: We comply with GDPR requirements for international data transfers, including use of Standard Contractual Clauses where applicable.

10. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or Service features.

Notification of Changes: Material changes will be communicated via:

• Email notification to your registered email address
• In-app notification upon login
• Prominent notice on our website

Your continued use of the Service after changes take effect constitutes acceptance of the revised Privacy Policy.