Privacy Policy

PicoDuel

1. Introduction

PicoDuel ("we," "us," or "our") provides this Privacy Policy to inform users ("you" or "your") of our practices regarding the collection, use, and disclosure of information when you use our application (the "App"). By accessing or using the App, you acknowledge that you have read, understood, and agree to this Privacy Policy. If you do not agree, do not use the App.

This Privacy Policy applies solely to the App and does not apply to any third-party services, websites, or platforms that may be linked to or accessible from the App, including but not limited to Telegram and the TON blockchain network.

2. Data Controller & Contact

The App is operated by inn3rGames, an independent developer acting as sole operator, who is the data controller responsible for the processing of your personal data. For any privacy-related inquiries or requests:
Email: hi@inn3r.com
Telegram: @inn3rGames

3. Information We Collect

3.1 Information Provided by You

• Authentication data. When you register or link a Telegram account: Telegram user ID, public display name, and profile photo URL. When you register or link a TON wallet: wallet address and public key.
• Username. The display name you choose or that is derived from your authentication method.
• Referral information. Referral code used during registration, if any.
• Purchase records. Transaction references, amounts, currencies, item identifiers, timestamps, and refund/chargeback status for Stars and GRAM purchases made through the App.
• Messaging data. Your Telegram chat identifier (used to deliver gameplay notifications), notification preferences, and the contents of system messages we send you.
• Moderation records. VIP status and expiry, refund counts, ban/suspension flags, and support correspondence.

3.2 Information Collected Automatically

• Gameplay data. Level, rank, grade, league, gold and ticket balances, upgrade levels, combat and duel history, win/loss records, streak data, monster campaign progress, leaderboard position, referral activity, and other gameplay-related metrics.
• Account metadata. Account creation date, last login date, login streak, session timestamps, and presence heartbeat timestamps used to compute the live online-player count.
• Technical data. IP address, device type, operating system, browser type and version, screen resolution, and general geographic location at country/city level. Collected through standard server logs.
• App performance data. Crash reports, error logs, and performance metrics used solely for technical diagnosis.

3.3 Information We Do NOT Collect

We do NOT collect your real name, email address, physical address, telephone number, government-issued identification number, financial account details, credit or debit card numbers, or biometric data. We do not track your browsing activity across other websites or applications. We do not use cookies, web beacons, or similar tracking technologies for advertising purposes.

3.4 Usage Analytics

We collect privacy-first, cookieless usage analytics through Umami Cloud (operated by Umami Software, Inc.; US and EU hosting regions available — see their privacy policy). This includes anonymous page views, session metadata (device type, browser, country), and aggregated gameplay events such as duels played, upgrades purchased, and rewards claimed. Sessions may be associated with a pseudonymous, app-internal account identifier so that your own sessions can be linked across visits — this identifier is never shared with third parties and is not used for advertising or cross-site tracking. We do not sell analytics data.

4. Purpose of Processing

We process your personal data for the following purposes:

• To provide and operate the App, including authentication, gameplay, leaderboards, progression, and messaging;
• To authenticate your identity via Telegram or TON wallet;
• To improve and maintain the App through aggregated usage and performance analysis;
• To prevent fraud, cheating, abuse, and violations of our Terms of Service;
• To communicate with you via in-app messages regarding your gameplay.

5. Data Sharing & Disclosure

We do NOT sell, rent, trade, or otherwise commercially transfer your personal data to any third party. We may share your data only in the following circumstances:

• Service providers. We use third-party providers to host and operate the App. They are contractually bound to use your data only as instructed by us. Analytics is processed by Umami Cloud (see Section 3.4).
• Advertising. Rewarded ads are served by TADS (tads.me), whose widget loads inside the App. Any data collected by the ad widget (such as device or advertising identifiers) is governed by TADS's own privacy policy.
• Wallet verification. When you pay with GRAM, your wallet address and transaction references are looked up through the TonAPI (tonapi.io) and TON Center (toncenter.com) APIs to verify payment. Their handling of that data is governed by their respective policies.
• Blockchain networks. If you use a TON wallet, your wallet address and transaction data are recorded on a public, immutable blockchain. We have no control over the TON blockchain network and assume no responsibility for the processing of your data by the blockchain or any third party. YOU ASSUME ALL RISK ASSOCIATED WITH THE USE OF PUBLIC BLOCKCHAIN TECHNOLOGY.
• Legal compliance. We may disclose your data if required by law, regulation, legal process, or governmental request.
• Protection of rights. We may disclose your data if we believe in good faith it is necessary to enforce our Terms of Service, protect our rights or property, or protect the safety of any person.
• Business transfer. In the event of a merger, acquisition, restructuring, or sale of assets, your data may be transferred as part of that transaction.

6. Data Retention

We retain your personal data for as long as your account is active or as needed to provide you with the App. There is currently no automatic purge of inactive accounts: your data is kept until you request deletion (see Section 7) or until we remove it.

The following cannot be deleted on request: records written to the public TON blockchain (immutable by design), database backups (which age out on rotation), data we must keep to comply with the law or resolve disputes, and aggregated, anonymised statistical data from which no individual user can be identified (retained indefinitely).

7. Your Rights

You may request access to, correction of, or deletion of your personal data by contacting us at hi@inn3r.com. We will respond within 30 days. To protect your account, we verify deletion requests with a message signed from your linked Telegram account or TON wallet before acting. Deletion is subject to the carve-outs in Section 6 (public blockchain records, backups, legal holds, and anonymised aggregates cannot be removed).

8. Data Security

We implement commercially reasonable technical and organisational measures to protect your personal data. However, no method of electronic storage or transmission is completely secure. WE CANNOT AND DO NOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR DATA. YOU PROVIDE YOUR DATA AT YOUR OWN RISK. WE ARE NOT RESPONSIBLE FOR ANY BREACH OF SECURITY BEYOND OUR REASONABLE CONTROL, INCLUDING BREACHES CAUSED BY THIRD-PARTY SERVICE PROVIDERS OR UNAUTHORISED ACCESS DESPITE OUR REASONABLE EFFORTS.

9. Cookies & Local Storage

The App sets no advertising cookies or similar tracking technologies of its own. Your browser's localStorage is used solely to store your session token (to keep you logged in) and your theme preference (light/dark mode). This data is stored locally on your device and is not accessible by any third party. Third-party widgets loaded inside the App — notably the TADS rewarded-ads widget — may use their own storage or identifiers as described in their privacy policies.

10. Children's Privacy

The App is not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal data from a child under 13, we will take reasonable steps to delete it. If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately.

11. Third-Party Services

The App integrates with Telegram, the TON blockchain, the TADS advertising network, and the TonAPI/TON Center verification APIs. We are not responsible for the privacy practices of these third parties. Your use of these services is governed by their respective privacy policies.

12. Disclaimer & Limitation of Liability

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL PICODUEL BE LIABLE FOR ANY LOSS, DAMAGE, OR UNAUTHORISED ACCESS TO YOUR PERSONAL DATA ARISING OUT OF OR RELATED TO: (A) YOUR USE OF THIRD-PARTY SERVICES, INCLUDING TELEGRAM AND THE TON BLOCKCHAIN; (B) YOUR FAILURE TO PROTECT YOUR ACCOUNT CREDENTIALS; (C) TRANSMISSION OF DATA OVER PUBLIC NETWORKS; (D) ACTIONS OF THIRD-PARTY SERVICE PROVIDERS; (E) ANY EVENT BEYOND OUR REASONABLE CONTROL. YOU ASSUME ALL RISK ASSOCIATED WITH THE USE OF THE APP AND THE INTERNET GENERALLY.

13. Changes to This Policy

We reserve the right to modify this Privacy Policy at any time. Changes are effective immediately upon posting. Your continued use of the App after any changes constitutes your acceptance of the updated policy.

14. Contact

Email: hi@inn3r.com