> For the complete documentation index, see [llms.txt](https://poremi.gitbook.io/poremi-docs/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://poremi.gitbook.io/poremi-docs/disclaimer/privacy-policy.md). # Privacy Policy Lazy Surfers Co., Ltd. and its affiliates (“we,” “our,” “us,” or the “Company”) are committed to protecting the privacy and security of the information we collect and to being transparent about how we collect, use, and process such information. This Privacy Policy describes our policies and practices regarding the collection, use, storage, disclosure, and protection of information that we collect from or about you. This Privacy Policy applies to the **Poremi application, related online services, blockchain services, and online communities operated by the Company that link to this Privacy Policy** (collectively, the “Services”). It is important that you read this Privacy Policy together with any other notices we may provide on specific occasions when we collect or process your personal data, so that you understand how and why we use your information and what rights you may have under applicable data protection laws. *** ## 1. Collection of Personal Data For the purposes of this Privacy Policy, **“personal data”** means any information relating to an identified or identifiable individual. When you use our Services, we may collect and process the following categories of personal data. #### Contact Information * Email address #### Registration and Technical Information * Authentication tokens issued by third-party login platforms (such as **Google** or **Apple**) * Poremi nickname * Wallet address * Encrypted wallet key * Technical information such as: * browser type * operating system * device type * IP address * device identifiers (including **ADID** and **IDFA**) #### Customer Support Information * Email address * Nickname * Information related to support inquiries, feedback, or complaints #### Blockchain Data The Services may interact with **public blockchain networks**. Transaction records recorded on blockchain networks are **publicly accessible and immutable**. Due to the nature of blockchain technology, such data cannot be deleted, modified, or controlled by the Company. Users acknowledge and accept that blockchain transactions may be publicly visible. *** We collect the above categories of information: * directly from you, * from other users of the Services, and * from third-party services and organizations (such as Google and Apple). Without this information, certain features of the Services may not function properly or may not be available. We **do not intentionally collect sensitive personal data**, including information relating to: * racial or ethnic origin * political opinions * religious or philosophical beliefs * trade union membership * health data * biometric identifiers unrelated to authentication * sexual orientation * criminal convictions or offences. *** ## 2. Use of Personal Data We may use your personal data for the following purposes. #### Service Provision To operate and maintain user accounts, provide the functionality of the Services, facilitate reward mechanisms such as the conversion of Points to **USDT**, personalize the user experience, and provide community or forum features. #### Service Improvement To maintain, analyze, test, and improve our Services, including troubleshooting technical issues and analyzing usage patterns. #### Platform Integrity and Security To detect and prevent fraudulent behavior, unauthorized program use, automated abuse, or other violations of our policies. #### Communication To send you service-related communications, including responses to inquiries, updates regarding your account, and important notices regarding the Services. #### Legal and Regulatory Compliance To comply with applicable legal obligations, including recordkeeping requirements, dispute resolution, enforcement of agreements, and protection of the Company’s legal rights. *** ## Legal Basis for Processing Where required by applicable law (such as under the **EU GDPR**), we process personal data based on the following legal bases: * performance of a contract with you * compliance with legal obligations * legitimate interests pursued by the Company or third parties, provided such interests are not overridden by your fundamental rights * your consent where required. *** ## 3. Automated Decision-Making and Profiling We do **not engage in profiling or automated decision-making** that produces legal or similarly significant effects on users. *** ## 4. Integrated Mission Ecosystem and Data Sharing The Poremi platform may provide access to advanced task interfaces and customized activities operated by third-party providers **(collectively, "Integrated Missions").** When a user chooses to participate in or interact with an **Integrated Mission,** the following principles apply. #### Data Sharing with Mission Providers To enable the proper tracking and calculation of rewards for **Integrated Missions,** we may provide limited user information to the respective provider, such as a unique user identifier, nickname, and relevant service usage data. Such sharing occurs only when a user **actively chooses to start or engage with a specific mission**. #### Termination of Mission Access If a user ceases participation in an **Integrated Mission** or revokes access from their account, we will terminate the provider’s access to the relevant user data where technically feasible. We may also request that the provider delete any user data previously shared with them. #### Third-Party Responsibility Information that users voluntarily provide directly within an **Integrated Mission interface,** or information independently collected by the provider, is governed by that provider’s own privacy policy. **The Company does not control and is not responsible for the data practices of third-party mission providers.** *** ## 5. Identity Verification and KYC Procedures To comply with international **Anti-Money Laundering (AML)** and **Counter-Terrorism Financing (CFT)** standards, certain users may be required to complete identity verification procedures. #### Third-Party Verification Providers Identity verification services may be provided by specialized third-party vendors (the **“KYC Providers”**). #### Information Collected During KYC During identity verification, users may be required to submit the following information directly to the KYC provider: * government-issued identification documents * facial recognition or liveness verification data * proof of residence documents #### Processing of KYC Data Sensitive identity verification data may be **processed and stored directly by the KYC provider’s secure infrastructure** rather than the Company’s servers. The Company typically receives only limited verification results, such as confirmation that verification has been successfully completed. #### Refusal or Failure of KYC If a user refuses to complete identity verification or submits inaccurate information, certain features of the Services, including the **conversion of Points to USDT or asset withdrawals**, may be restricted or suspended. *** ## 6. Disclosure of Personal Data We may share your personal data with third parties in the following circumstances. #### Service Providers We may engage third-party vendors to assist with hosting services, cloud storage, analytics, identity verification, technical infrastructure, or customer support. #### Corporate Transactions In the event of a merger, acquisition, restructuring, sale of assets, financing, or similar corporate transaction, user information may be transferred as part of the transaction. #### Legal Requirements We may disclose information to law enforcement agencies, regulators, courts, or government authorities when required by law or when reasonably necessary to protect the Company’s legal rights. *** ## 7. Data Security and Limitation of Liability We implement reasonable administrative, technical, and organizational measures to protect personal data against unauthorized access, loss, misuse, or alteration. However, no system can be guaranteed to be completely secure. The Company shall not be liable for damages resulting from circumstances beyond its reasonable control, including but not limited to: #### User Responsibility Loss or disclosure of information resulting from a user’s failure to protect their login credentials, private keys, seed phrases, or other security information. #### Blockchain Limitations Security vulnerabilities, forks, or structural characteristics of blockchain networks that may result in public disclosure of transaction data. #### Third-Party Services Incidents arising from third-party **Integrated Mission providers** or external services not operated by the Company. *** ## 8. Data Retention We retain personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required by law. Generally, the following retention periods apply. #### Users with Activity or Assets Information of users who have activity history, transaction records, or remaining assets may be retained for **up to five (5) years** following termination of the user relationship. #### Customer Support Records Information related to user support inquiries may be retained for **up to three (3) years**. #### Incomplete Account Registration Information relating to incomplete account registrations may be retained for **up to sixty (60) days**. Where applicable laws require longer retention, we will retain the data for the legally required period. *** ## 9. Your Rights Subject to applicable data protection laws, you may have the following rights regarding your personal data. * Request access to your personal data * Request correction or deletion of inaccurate information * Request restriction of processing * Request data portability in a machine-readable format * Object to certain types of data processing * Withdraw consent where processing is based on consent To exercise your rights, please contact us using the contact details provided below. We may request additional information to verify your identity before responding to your request. *** ## 10. Children The Services are **not intended for individuals under the age of 19**, and we do not knowingly collect personal data from minors without appropriate legal authorization. If we become aware that we have collected personal data from a minor in violation of applicable laws, we will take appropriate steps to delete such information. *** ## 11. Data Controller and Contact Information Lazy Surfers Co., Ltd. is the **data controller** for the purposes of the **EU GDPR, UK GDPR, and other applicable data protection laws**. If you have any questions regarding this Privacy Policy or our handling of your personal data, you may contact us at: Email\ *** ## 12. Changes to this Privacy Policy We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or services. If we make material changes to this Privacy Policy, we will take reasonable steps to notify users, such as by posting a notice within the Services or updating the **“Last Updated”** date at the top of this Policy. --- # Agent Instructions This documentation is published with GitBook. GitBook is the documentation platform designed so that both humans and AI agents can read, navigate, and reason over technical content effectively. 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