Privacy Policy

1. Who we are

Sentinel Software Limited is the data controller responsible for your personal data. We operate the SkillGames.AI platform from the United Kingdom.

• Legal name: Sentinel Software Limited
• Registered address: 19 New Road, Brighton, BN1 1UF, United Kingdom
• Data Protection Officer: dpo@sentinelactive.com

2. What data we collect

We collect personal data that you provide directly, data generated through your use of the Platform, and limited technical data required to operate the service securely.

• Account data: email address, display name, username, profile preferences, and authentication records.
• Gameplay data: match history, moves, ratings, challenge invitations, friend connections, and in-app notifications.
• Payment data: purchase history, wallet balance, transaction records, cryptocurrency payout addresses you provide, and on-chain transaction identifiers. Payments are processed via a third-party crypto payment processor; we do not hold your private keys.
• Communications: emails we send to you (such as turn reminders and challenge invitations) and support correspondence.
• Technical data: IP address, browser type, device information, session identifiers, and server logs used for security, fraud prevention, and service reliability.
• Cookies and similar technologies: see Section 6 below.

3. How we use your data

We use your personal data only where we have a lawful basis under UK GDPR. The main purposes are:

• To create and manage your account (contract).
• To operate matches, challenges, ratings, and social features such as friends (contract).
• To process cryptocurrency credit purchases, prize competitions, and cash-outs where enabled, including identity verification and anti-money-laundering checks (contract and legal obligation).
• To send service notifications, including turn reminders and match updates (contract and legitimate interests).
• To maintain platform security, detect abuse, and enforce our Terms & Conditions (legitimate interests and legal obligation).
• To comply with applicable laws, respond to lawful requests, and resolve disputes (legal obligation).
• To improve the Platform through aggregated analytics where this does not identify you (legitimate interests).

4. Marketing communications

We do not sell your personal data. We may send you service-related emails that are necessary to operate your account. Where we send optional marketing communications, we will do so only with your consent and you may opt out at any time.

5. Who we share data with

We share personal data only where necessary and under appropriate safeguards:

• Our crypto payment processor — processing cryptocurrency deposits for credit purchases and cash-out payouts.
• SendGrid (Twilio) — delivery of transactional and notification emails.
• Cloud infrastructure and hosting providers that store and process data on our behalf under data processing agreements.
• Professional advisers, regulators, or law enforcement where required by law or to protect our legal rights.

6. Cookies and similar technologies

We use essential cookies and local storage to keep you signed in, maintain session security, and remember your preferences. We may use analytics cookies to understand how the Platform is used; where required, we will request your consent before setting non-essential cookies. You can control cookies through your browser settings, although disabling essential cookies may affect Platform functionality.

7. International transfers

Your data is primarily processed in the United Kingdom and the European Economic Area. Where we transfer data outside the UK, we ensure appropriate safeguards are in place, such as UK adequacy regulations, Standard Contractual Clauses, or equivalent mechanisms approved under UK data protection law.

8. Data retention

We retain personal data only for as long as necessary for the purposes described in this policy:

• Account and profile data — while your account is active and for a reasonable period after closure to resolve disputes and meet legal obligations.
• Match and gameplay records — retained for integrity of ratings, dispute resolution, and fair play enforcement.
• Payment and transaction records — retained as required for accounting, tax, and anti-money laundering purposes.
• Server logs and security records — typically retained for up to 12 months unless a longer period is required for investigation.

9. Your rights

Under UK GDPR, you have the following rights in relation to your personal data:

• Right of access — request a copy of the personal data we hold about you.
• Right to rectification — request correction of inaccurate or incomplete data.
• Right to erasure — request deletion of your data in certain circumstances.
• Right to restrict processing — request that we limit how we use your data in certain circumstances.
• Right to data portability — receive your data in a structured, commonly used format where applicable.
• Right to object — object to processing based on legitimate interests, including profiling where applicable.
• Right to withdraw consent — where processing is based on consent, you may withdraw it at any time.
• Right to lodge a complaint — with the Information Commissioner's Office (ICO) at ico.org.uk if you believe we have not handled your data properly.

10. Children

The Platform is not intended for anyone under 18 years of age. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will take steps to delete it.

11. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. No method of transmission over the internet is completely secure; we encourage you to use a strong, unique password and keep access to your email account secure.

12. Automated decision-making

We do not use automated decision-making or profiling that produces legal or similarly significant effects on you. Match outcomes and ratings are determined by gameplay rules and player actions, not automated profiling of personal characteristics.

13. Changes to this policy

We may update this Privacy Policy from time to time. We will post the updated version on the Platform and, where changes are material, notify you by email or through an in-app notice. The "Last updated" date at the top indicates when this policy was last revised.

14. Contact us

If you have questions about this Privacy Policy or how we handle your personal data, contact our Data Protection Officer at dpo@sentinelactive.com or write to: Data Protection Officer, Sentinel Software Limited, 19 New Road, Brighton, BN1 1UF, United Kingdom.