Privacy Policy

This Privacy Policy explains how Cryptogameplan LLC (“Crypto Gameplan,” “we,” “our,” or “us”) collects, uses, stores, discloses, and protects personal information when you visit our website, use our mobile app, submit forms, apply for our mentoring program, book calls, use our customer platforms, communicate with us, participate in private communities, or otherwise interact with our services.

This Privacy Policy applies to crypto-gameplan.com, its subdomains, including customer-accessible platforms such as terminal.crypto-gameplan.com and account.crypto-gameplan.com, to the CryptoGameplan mobile app for Android and iOS, and to our related forms, communications, customer support, email, SMS, Telegram, and social media interactions.

This Privacy Policy does not apply to websites, platforms, services, payment providers, video platforms, messaging platforms, social media platforms, or other third-party services that we do not own or control. When you interact with a third-party service, that third party’s own terms and privacy policy may apply.

1. CONTROLLER AND CONTACT INFORMATION

The controller responsible for the personal information described in this Privacy Policy is:

Cryptogameplan LLC, 30 N Gould St Ste R, Sheridan, Wyoming 82801, United States. Email: [email protected]

Where a third-party platform or provider acts as an independent controller under its own privacy policy, that third party is responsible for its own processing of personal information.

2. SCOPE AND AGE RESTRICTION

Our services, including the mobile app, are intended only for individuals who are at least 18 years old.

We do not knowingly collect personal information from anyone under the age of 18. If we learn that we have collected personal information from a person under 18, we will take reasonable steps to delete that information.

3. PERSONAL INFORMATION WE COLLECT

We collect personal information directly from you, automatically through our systems, and from third-party platforms when you interact with us there.

3.1 Contact and Identity Data

We may collect:

• first name, last name, and other identifying information;

• email address;

• phone number;

• postal address, including street, house number, postal code, province, and country, where you provide it in your profile or for billing;

• your account identifier and time zone;

• profile picture, where you choose to upload one;

• Telegram username, social media handle, or other contact identifiers;

• communication preferences;

• email and SMS consent choices.

3.2 Application and Intake Data

If you apply for Crypto Gameplan or submit one of our application forms, we may collect information such as how long you have been investing in crypto, how you currently manage your crypto portfolio, your approximate total crypto portfolio value, your biggest challenge with crypto investing, what you have already tried, what a systematic approach would change for you, your commitment level, your reason for applying, free-text responses you choose to provide, your preferred way to hear from us, your email address and phone number, and your SMS consent choices.

This information may relate to your financial circumstances, investment experience, goals, preferences, and self-reported challenges. We use it to review applications, understand whether there may be a mutual fit, prepare for calls, communicate with you, and improve our application and onboarding process.

We do not ask you to provide wallet private keys, seed phrases, exchange passwords, or direct access credentials.

3.3 Booking and Communication Data

We may collect appointment and scheduling information, call-confirmation details, email communications, SMS records, support messages and support tickets created in the app, Telegram messages, social media messages, onboarding communications, customer service interactions, and timestamps and communication metadata.

3.4 Customer Account and Platform Data

When you use customer-accessible platforms such as Terminal, Campus, or the mobile app, we may collect:

• login email address;

• one-time password authentication events and, where enabled, two-factor authentication status;

• access-control records, customer status, role and permission information;

• platform access logs and protected-content access records;

• learning progress, lesson completions, streaks, and search queries you enter in Campus;

• portfolio positions, transactions, and related entries you record in Terminal;

• images you upload for the optional AI-assisted portfolio import;

• support and troubleshooting information.

Users who do not have customer access may be redirected to an access page and will not be able to access protected customer content.

3.5 Mobile App and Device Data

When you use our mobile app, we may additionally collect:

• a push notification token issued by the operating system and the push service, used to deliver notifications and to keep your session current;

• device and app information such as app version, operating system version, and device model;

• content you download for offline use, which is stored in encrypted form on your device, bound to your account, and time-limited.

The app requests camera and photo library access only when you choose to set a profile picture or use the AI-assisted portfolio import. The app does not record audio, does not access your location, and does not read your contacts.

3.6 Technical, Device, Logging, and Security Data

When you visit our website or use our platforms, we may automatically collect technical and usage information, including IP address, browser type and version, device type, operating system, referring URLs, pages viewed, timestamps, request paths or endpoints, authentication and login-related events, access status, server logs, error logs, security logs, request logs, performance logs, trace data, application events, API request metadata, and diagnostic information.

We use logging, monitoring, metrics, and tracing tools to operate, secure, debug, and improve our website, customer platforms, infrastructure, and applications.

We do not intentionally collect sensitive credentials, private keys, seed phrases, wallet passwords, full payment card numbers, or account passwords in logs or traces. However, logs, error messages, request metadata, or trace attributes may incidentally contain personal information depending on how a user interacts with our services or how an error occurs.

The mobile app does not currently send crash reports or diagnostic telemetry to us. If we enable crash reporting in a future version, we will update this Privacy Policy and the corresponding app store data disclosures before doing so.

3.7 Payment and Transaction Data

We may collect or process payment status, billing records, invoice information, transaction references, payment amount, refund or dispute information, wire transfer references, blockchain transaction hashes, wallet addresses or similar identifiers if they are provided to us or become visible in connection with a transaction or support request, and communication related to payments.

We do not store full payment card numbers on our own systems when payments are processed through Stripe.

No purchases are made inside the mobile app. Access is granted through our website and customer platforms.

3.8 Media and Testimonial Data

Where you have provided permission or authorization, we may process written testimonials, names, photos, videos, likeness, role, title, or related professional information, and other media or statements approved for publication.

4. INFORMATION FROM THIRD-PARTY PLATFORMS

If you contact us through Instagram, YouTube, TikTok, X, LinkedIn, Telegram, or another third-party platform, we may receive your profile name, username or handle, public profile information, message content, timestamps, and information you choose to provide during the conversation.

We may transfer relevant lead or customer communication information into GoHighLevel, Google Workspace, or our internal systems to respond to your request, manage our relationship with you, and provide our services.

Third-party platforms process your information according to their own terms and privacy policies.

5. HOW WE USE PERSONAL INFORMATION

We use personal information for the following purposes:

• to provide, operate, and improve our website, mobile app, customer platforms, and services;

• to receive and review applications and determine whether there may be a mutual fit;

• to process inquiries, respond to messages, and manage support tickets;

• to manage leads, applicants, customers, onboarding, and support;

• to schedule appointments, send reminders, and confirm calls by email or SMS;

• to send service-related emails, SMS messages, push notifications, and support communications;

• to send marketing emails or promotional messages where permitted by law and your communication preferences;

• to manage access to private customer areas, including Terminal, Campus, the mobile app, Telegram groups, and related services;

• to display and maintain your learning progress and your recorded portfolio;

• to process an image you submit for AI-assisted portfolio import, where you have given the required consent;

• to process payments, invoices, refunds, disputes, and transaction records;

• to maintain security, prevent abuse, investigate technical issues, debug errors, monitor performance, and protect our systems;

• to document email and SMS opt-ins, opt-outs, and communication preferences;

• to comply with legal, tax, accounting, regulatory, and contractual obligations;

• to enforce our terms, policies, and rights;

• to use testimonials, names, photos, videos, or similar media only where we have appropriate permission or authorization.

6. LEGAL BASES FOR PROCESSING

Where laws such as the GDPR, UK GDPR, or similar privacy laws apply, we rely on one or more of the following legal bases.

• Reviewing applications, responding to inquiries, determining mutual fit, and scheduling calls: steps before entering into a contract; legitimate interests.

• Providing services, customer access, onboarding, support, and account functionality, including the mobile app: performance of a contract; legitimate interests.

• Sending transactional emails, transactional SMS, and service-related push notifications: performance of a contract; legitimate interests; consent where required.

• Sending marketing emails and promotional SMS: consent where required by law; legitimate interests where permitted by law; always subject to opt-out rights.

• Processing an image for AI-assisted portfolio import: consent, which you give in the app before the feature can be used and which you can withdraw.

• Processing payments, invoices, refunds, disputes, crypto payments, and wire transfers: performance of a contract; legal obligations; legitimate interests.

• Maintaining security, preventing abuse, debugging errors, monitoring performance, and operating infrastructure: legitimate interests; legal obligations where applicable.

• Maintaining business, tax, accounting, compliance, and dispute records: legal obligations; legitimate interests.

• Publishing testimonials, names, images, videos, or similar media: consent or other authorization, where applicable.

You may withdraw consent at any time where we rely on consent. Withdrawal does not affect the lawfulness of processing before withdrawal.

7. REQUIRED INFORMATION AND CONSEQUENCES OF NOT PROVIDING IT

Some personal information is necessary for us to review your application, respond to inquiries, schedule calls, create or administer customer access, process payments, provide services, send required communications, maintain security, or comply with legal obligations.

If you do not provide information that is required for a specific purpose, we may not be able to proceed with your application, book or confirm a call, grant access to customer platforms or the mobile app, process a payment, provide support, or deliver our services.

8. PAYMENTS AND BILLING

We may accept payments through Stripe, cryptocurrency payments, wire transfers, or other payment and billing methods. Purchases are not made inside the mobile app.

8.1 Stripe Payments

If you pay through Stripe, Stripe may process payment and transaction information, including your name, email address, phone number, billing details, payment method information, transaction amount, payment status, refund information, dispute information, fraud-prevention information, and other information necessary to process the transaction.

Stripe may act as our service provider or processor for certain payment processing activities and as an independent controller for certain compliance, fraud prevention, reporting, and regulatory purposes under its own terms and privacy policy.

We do not store full credit card numbers on our own systems when payments are processed through Stripe.

8.2 Cryptocurrency Payments

If you pay with cryptocurrency, we may process invoice information, payment amount, wallet address if provided or visible as part of the transaction, transaction hash, payment status, the blockchain network used, and communication related to the payment.

Cryptocurrency transactions may be recorded on public blockchains. Public blockchain information may be visible to third parties and cannot generally be deleted, changed, or reversed by us.

You should never send us private keys, seed phrases, wallet passwords, exchange credentials, or other sensitive wallet access information.

8.3 Wire Transfers

If you pay by wire transfer, your bank, our bank, intermediary banks, and related financial institutions may process your name, bank account details, payment amount, payment reference, transaction date, and other information necessary to complete the transfer.

8.4 Billing, Tax, and Accounting Records

We may retain payment, invoice, refund, transaction, crypto payment, wire transfer, and accounting records as necessary to provide our services, resolve disputes, prevent fraud, and comply with legal, tax, accounting, and regulatory obligations.

9. EMAIL MARKETING

We may send newsletters, broadcasts, follow-ups, educational content, service updates, and promotional emails through GoHighLevel or related email systems.

Marketing emails include an unsubscribe option. You can unsubscribe at any time by using the unsubscribe link included in our marketing emails or by contacting us at [email protected].

Transactional, account-related, support, security, payment-related, or legally required emails may still be sent where necessary.

10. SMS/TEXT MESSAGING

Crypto Gameplan may offer SMS/text messaging for appointment reminders, call confirmations, application updates, onboarding, customer support, program updates, and promotional messages where you have opted in or where otherwise permitted by law.

10.1 SMS Consent

SMS consent is collected through website forms, CRM forms, scheduling flows, Typeform forms, or other opt-in forms. Where applicable, SMS consent is collected separately from other consents and is not required as a condition of purchasing our services.

10.2 Types of SMS Messages

Depending on your consent and interactions with us, you may receive appointment reminders, call confirmations, application updates, scheduling updates, customer support updates, onboarding reminders, program or service updates, and promotional or marketing messages if you opted in to receive them.

10.3 Message Frequency and Charges

Message frequency varies based on your interactions with us and the services you use. Message and data rates may apply depending on your mobile carrier and plan. Crypto Gameplan is not responsible for charges imposed by your mobile carrier.

10.4 Opting Out

You may opt out of SMS messages at any time by replying STOP to any message you receive from us. After opting out, you may receive a one-time confirmation message. You will not receive further SMS messages unless you opt in again. For help, reply HELP or contact us at [email protected].

10.5 No Sharing of SMS Consent

We do not sell, rent, lease, trade, or otherwise share your phone number or SMS opt-in consent with third parties or affiliates for their own marketing purposes.

SMS-related information, including your phone number and opt-in or opt-out status, is shared only with our CRM, messaging providers, telecommunications providers, or service providers as necessary to deliver messages, manage consent, maintain suppression lists, and comply with applicable requirements.

11. PUSH NOTIFICATIONS

If you allow notifications in the mobile app, the operating system issues a push token that identifies your app installation on your device. We use it to deliver notifications about new content and account activity, and to prompt the app to refresh your session.

The push token is tied to your account while you are signed in. When you sign out or switch accounts, we remove that association. You can turn notifications off at any time in your device settings, which stops delivery.

12. COOKIES, TRACKING, AND EMBEDDED CONTENT

We may use cookies and similar technologies that are necessary for website operation, security, authentication, platform access, fraud prevention, and technical functionality.

Based on our current implementation, we do not intentionally use website analytics trackers, advertising pixels, retargeting pixels, session replay tools, or behavioral advertising technologies such as Google Analytics, Meta Pixel, TikTok Pixel, LinkedIn Insight Tag, X Pixel, Hotjar, or similar tools on our website, customer platforms, or mobile app. The mobile app does not use an advertising identifier.

However, our website may include third-party embedded content, such as embedded Vimeo videos. Embedded content may cause the relevant third-party provider to process technical, device, browser, usage, or cookie-related information according to its own terms and privacy policy.

Where practical, we may use privacy-enhancing player settings for embedded videos. Where applicable law requires consent for non-essential cookies, tracking technologies, or similar technologies, we will request it before such technologies are used.

If we add analytics, advertising pixels, retargeting, session replay, or other non-essential tracking technologies in the future, we will update our practices and, where required, request consent before such technologies are activated.

13. THIRD-PARTY SERVICE PROVIDERS AND PLATFORMS

We use third-party service providers and platforms to operate our business, website, mobile app, customer platforms, communications, payments, logging, monitoring, tracing, and infrastructure. These providers may process personal information on our behalf or as independent controllers, depending on the context.

Our current service providers and platforms include:

• GoHighLevel: CRM, email communications, SMS messaging, scheduling, reminders, lead and customer management.

• Typeform: forms, questionnaires, application intake, and form submissions.

• Google Workspace: business email, documents, internal administration, customer communication, and file storage.

• Cloudflare: DNS, security, CDN, traffic routing, protection against abuse, technical logs, and the storage and delivery of images and video used in our platforms and mobile app, including profile pictures and lesson media.

• Google (Gemini): AI-assisted extraction of portfolio data from a file or image you submit for import. This feature is optional and requires your consent before an image is processed.

• Expo: delivery of push notifications to your device.

• Framer: website hosting and landing page delivery.

• Hetzner: self-managed infrastructure and virtual machines hosted in Germany.

• Dash0: logging, metrics, tracing, observability, application performance monitoring, infrastructure monitoring, debugging, incident investigation, and alerting.

• Vimeo: embedded video hosting and playback.

• Telegram: private customer groups, private chats, support, updates, and customer communication.

• Stripe: payment processing, transaction processing, refunds, disputes, fraud prevention, and billing support.

• Google Play and the Apple App Store: distribution of the mobile app and delivery of app updates.

• Banks and wire transfer providers: wire transfer processing, payment confirmation, and financial records.

• Blockchain networks and crypto payment infrastructure: cryptocurrency payment confirmation and transaction records.

• Instagram, YouTube, TikTok, X, LinkedIn: social media presence, direct messages, lead communication, and customer inquiries.

• Professional advisors: legal, tax, accounting, compliance, and business advisory services.

Framer is used primarily for hosting and delivering our landing page. Customer data submitted through embedded forms or calendars is generally processed through tools such as Typeform or GoHighLevel, not stored directly in Framer as customer form records.

Some of these providers act as processors or service providers that process personal information on our behalf. Others may act as independent controllers under their own privacy policies, including certain payment providers, banks, blockchain networks, app stores, social media platforms, Telegram, and embedded media providers depending on the context.

Where required by applicable privacy and data protection laws, we enter into data processing agreements, data processing addenda, or equivalent contractual safeguards with service providers that process personal information on our behalf. These agreements are intended to ensure that such service providers process personal information only in accordance with our instructions, implement appropriate security measures, assist with applicable privacy obligations, and use subprocessors only as permitted under the applicable agreement.

14. HOW WE SHARE PERSONAL INFORMATION

We may share personal information with:

• service providers and processors that help us operate our website, mobile app, platforms, CRM, email, SMS, push notifications, scheduling, hosting, infrastructure, forms, videos, payments, logging, monitoring, tracing, and support;

• payment processors, banks, crypto payment infrastructure, blockchain networks, and financial institutions as necessary to process or verify payments;

• telecommunications and messaging providers for SMS delivery and consent management;

• tax, accounting, bookkeeping, billing, or invoicing providers;

• professional advisors such as lawyers, accountants, compliance advisors, and auditors;

• authorities, courts, regulators, banks, payment networks, or law enforcement where required by law or necessary to protect our rights;

• successors or parties involved in a business transaction, such as a merger, acquisition, financing, restructuring, or sale of assets;

• third parties where you have given us permission or instructed us to share the information.

We do not sell your personal information. We do not share your personal information with third parties for their own marketing purposes. We also do not share SMS opt-in consent or phone numbers with third parties or affiliates for their own marketing purposes.

15. INTERNATIONAL DATA TRANSFERS

Crypto Gameplan is based in the United States and operates from the United States.

We use infrastructure and service providers located in the United States, Germany, the European Economic Area, and other countries. This means personal information may be transferred to, stored in, or processed in countries other than the country where you are located.

Where applicable law requires a transfer mechanism, we rely on appropriate safeguards such as adequacy decisions, the EU-U.S. Data Privacy Framework and UK Extension where applicable, Standard Contractual Clauses, data processing agreements, contractual safeguards, or other lawful transfer mechanisms available under applicable law.

You may contact us at [email protected] if you would like more information about the safeguards used for international transfers where applicable.

16. DATA RETENTION

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention periods may depend on the type of information, whether you are a lead, applicant, customer, former customer, newsletter subscriber, or support contact, whether the information is needed to provide services or maintain customer access, whether it is needed for legal, tax, accounting, security, dispute, or compliance purposes, whether you have withdrawn consent or opted out of marketing communications, whether we must retain opt-out or suppression records to respect your communication preferences, the sensitivity of the information, and operational needs such as backups, security logs, debugging, and fraud prevention.

Examples include:

• lead, inquiry, and application records may be kept while we have an active business relationship or legitimate business need;

• customer records may be kept for the duration of the customer relationship and as needed afterward for legal, tax, accounting, support, or dispute purposes;

• SMS and email opt-in and opt-out records may be kept as necessary to demonstrate consent and maintain suppression lists;

• support, ticket, and Telegram communication records may be kept as needed to provide support, document customer communication, and protect our rights;

• payment, invoice, refund, transaction, crypto payment, and wire transfer records may be kept for legally required accounting, tax, fraud prevention, and dispute-resolution periods;

• server logs, security logs, application logs, metrics, and traces are kept for a limited period unless needed for security, debugging, fraud prevention, performance monitoring, legal compliance, or dispute resolution;

• content downloaded for offline use in the mobile app is stored on your device in encrypted form, remains bound to your account, expires after a limited period, and is removed when you sign out, lose access, or delete the app;

• backups may retain information for a limited period according to our backup and disaster recovery practices.

17. SECURITY

We use reasonable technical, organizational, and administrative measures designed to protect personal information against unauthorized access, disclosure, loss, misuse, alteration, and destruction.

These measures may include access controls, authentication, one-time password login, two-factor authentication where enabled, infrastructure security, encrypted connections, encrypted storage of offline content on your device, restricted administrative access, logging, monitoring, backups, and security practices for our self-managed infrastructure.

No method of transmission or storage is completely secure. We cannot guarantee absolute security.

18. AUTOMATED DECISION-MAKING AND PROFILING

We may use your application responses to review your application, understand whether there may be a mutual fit, and prepare for calls or onboarding.

The optional AI-assisted portfolio import uses automated processing to read the file or image you submit and propose transaction entries. You review and confirm those entries before anything is saved, so the processing does not make a decision about you.

We do not currently use solely automated decision-making, including profiling, that produces legal effects or similarly significant effects about you without human involvement. If we introduce automated scoring, profiling, AI-based application review, or similar automated decision-making in the future, we will update this Privacy Policy where required.

19. YOUR PRIVACY CHOICES AND RIGHTS

Depending on where you live and which laws apply, you may have rights regarding your personal information, including the right to request access, request correction, request deletion, request restriction of certain processing, object to certain processing, request portability, withdraw consent where processing is based on consent, opt out of marketing emails, opt out of SMS messages, and lodge a complaint with a supervisory authority where applicable.

You have the right to object to direct marketing at any time. If you object to direct marketing, we will stop using your personal information for that purpose.

To exercise your rights, contact us at [email protected].

We may need to verify your identity before processing a request. We may deny or limit requests where permitted by law, including where fulfilling the request would conflict with legal obligations, security obligations, fraud prevention, dispute resolution, accounting requirements, tax requirements, contractual obligations, or the rights of others.

19.1 Deleting Your Account

You can request deletion of your account and its associated data at any time, without signing in, using our account deletion page:

https://account.crypto-gameplan.com/account-deletion

We confirm the request by email before anything is deleted. Certain records may be retained where a legal, tax, accounting, security, or dispute-resolution obligation requires it, as described in the Data Retention section.

20. U.S. STATE PRIVACY RIGHTS

Depending on your U.S. state of residence and whether applicable state privacy laws apply to us, you may have additional rights regarding your personal information, including the right to know, access, correct, delete, or receive a copy of certain personal information, and the right to opt out of certain types of processing.

We do not sell personal information. Based on our current implementation, we do not share personal information for cross-context behavioral advertising or targeted advertising using tracking pixels or similar technologies.

We do not knowingly sell or share the personal information of individuals under 16 years of age.

To submit a privacy request, contact us at [email protected].

21. EEA, UK, SWITZERLAND, AND SIMILAR INTERNATIONAL PRIVACY RIGHTS

If you are located in the European Economic Area, the United Kingdom, Switzerland, or another jurisdiction with similar privacy rights, the rights described in this section apply to the extent required by applicable law.

Where applicable, you may have the right to access your personal information, correct inaccurate or incomplete information, request deletion, restrict processing, object to processing based on legitimate interests, object to direct marketing, receive a copy of certain information in a portable format, withdraw consent at any time where processing is based on consent, and lodge a complaint with a supervisory authority.

To exercise these rights, contact us at [email protected].

22. THIRD-PARTY LINKS, PLATFORMS, AND EMBEDDED CONTENT

Our website, mobile app, customer platforms, emails, Telegram groups, and social media profiles may link to or integrate third-party services, websites, videos, payment providers, messaging platforms, or social media platforms.

This includes Vimeo videos, Telegram, social media platforms, forms, scheduling tools, Stripe, banks, blockchain networks, app stores, and other third-party services.

We are not responsible for the privacy practices, terms, or content of third-party services that we do not own or control. Please review the privacy policies of those third-party services before providing information to them.

23. TELEGRAM AND PRIVATE COMMUNITY COMMUNICATION

We may use Telegram for private customer groups, private chats, support, onboarding, updates, and customer communication.

Information you post or send on Telegram may be visible to us and, depending on the group or chat, to other participants. Telegram is a third-party platform and processes information according to its own terms and privacy policy.

Please avoid sharing sensitive credentials, private keys, seed phrases, passwords, wallet recovery information, exchange credentials, unnecessary screenshots, or unnecessary personal information in Telegram groups or chats.

24. TESTIMONIALS, IMAGES, AND VIDEOS

We may publish testimonials, names, images, videos, titles, or related information only where we have appropriate permission or authorization.

You may contact us at [email protected] if you have questions about a testimonial or media item involving you.

25. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. The updated version will be posted on our website with a revised “Last updated” date.

If we make material changes, we may provide additional notice where required by law or appropriate under the circumstances.

26. CONTACT US

If you have questions, requests, or concerns about this Privacy Policy or our privacy practices, contact us at:

Cryptogameplan LLC, 30 N Gould St Ste R, Sheridan, Wyoming 82801, United States. Email: [email protected]