LEGAL · /privacy

Privacy Policy

This Privacy Policy explains how the operator of the Encore software (the "Operator") processes personal data of users of the software, waitlist applicants and referral partners (each, the "user") in connection with the software (the "Service"). The Operator processes personal data in accordance with Federal Law No. 152-FZ "On Personal Data".

1. Operator (data controller)

The Service is operated by an Individual Entrepreneur whose full details (name, OGRNIP, INN) are set out in the Public Offer. For any privacy-related request, contact: support@encoresoft.io.

2. Data collected

Account data: full name, country of residence, email address and, where applicable, the user's Discord identifier.

Waitlist data: the Discord identifier, username and account creation date; the list of Discord servers the user belongs to, used to check membership in partner communities (only the names of shared servers are stored); the answers given in the application form; a device fingerprint (a hash of browser, device, screen, graphics and time zone parameters); the result of a VPN check, the location and the network provider determined from the IP address; whether the account has an avatar and is a member of the Encore Discord server for licensees; and a trust score calculated from these data. On submission the user is added to the Encore waitlist Discord server, unless the Discord account or the IP address is on the Operator's block list.

Referral partner data: for referral partners — the Discord identifier, contact details, wallet address, the number of referrals and accrued rewards.

Identity data: where the Operator requests it, data from an identity document and proof of non-resident status in the Russian Federation.

Payment data: for each payment the Operator records the transaction hash, the network, the asset, the amount, the wallet address the payment was sent from, and the resulting subscription status. The Operator does not accept bank cards and does not collect or store bank card or bank account details.

Technical data: IP address and the region determined from it, device and browser information, and usage data collected automatically during use of the waitlist, the dashboard and the Service.

Cookies: small files stored by the browser to keep the Service working and to understand usage.

3. Purposes of processing

  • to provide the Service and the subscription;
  • to send Service notifications and notifications on the status of the user's tasks (queue position, cart status);
  • to confirm cryptocurrency payments in the blockchain and to issue invoices;
  • to verify non-resident status in the Russian Federation, including by comparing the region determined from the IP address with the stated country of residence, and to screen against sanctions lists;
  • to confirm the source of funds and the substance of transactions to banks and exchange operators;
  • to review waitlist applications, add applicants to the Encore waitlist Discord server, notify applicants of the decision, remind approved applicants to complete the payment, credit the referral partner named in the application and prevent repeated or automated applications;
  • to credit and pay referral rewards to referral partners;
  • to provide support and respond to requests;
  • to maintain the security and stability of the Service;
  • to comply with legal obligations.

Some waitlist applications are decided automatically: an application is rejected when it fails checks (Discord account age, a repeated application, a block-list match) and may be approved when its trust score meets the set threshold. The applicant may object to a rejection at support@encoresoft.io, and the application will then be reviewed by a person.

4. Legal basis

Personal data is processed on the basis of the user's consent, given separately at sign-up or when submitting a waitlist application, and where processing is necessary to perform the agreement with the user (the Public Offer) or with a referral partner, or to comply with the law.

5. Sharing with third parties

Data is shared only with the following recipients and only to the extent necessary:

  • public blockchain networks — a payment transaction, its amount and the wallet addresses involved are recorded in a public blockchain, are visible to anyone and cannot be deleted or altered by the Operator;
  • Discord — sign-in and checks for waitlist applications, and community features;
  • hosting, cloud storage, messaging and analytics providers that operate the infrastructure of the waitlist, the dashboard and the Service;
  • the referral partner named in a waitlist application — the applicant's Discord username, when the applicant purchases a license;
  • the provider of the dashboard (licensing and payment software) — account, license and payment data and, for approved waitlist applicants, the Discord identifier or username to check whether a license has been purchased;
  • anti-fraud providers — IP address checks (location and VPN detection) for waitlist applications;
  • blockchain analytics (AML) providers — wallet addresses and transaction hashes, to screen incoming payments;
  • banks and exchange operators — the user's details, the payment transaction hashes and the invoices may be disclosed to them to confirm the source of funds and the substance of the transaction;
  • competent authorities — where required by law.

Some of these recipients, including Discord, referral partners, the provider of the dashboard and hosting, cloud storage, messaging, analytics, anti-fraud and AML providers, are located outside the Russian Federation. The Operator does not sell personal data.

6. Storage and retention

Personal data is stored for as long as the account or, for referral partners, the referral arrangement is active and for the period required by applicable law, after which it is deleted or anonymized. Waitlist data of applicants who do not purchase a license is stored until the purposes of processing are achieved — the review of the application and the prevention of repeated applications — and is then deleted; block-list entries are kept while the block applies.

7. User rights

The user may:

  • request access to their personal data and information about its processing;
  • request correction of inaccurate data;
  • request deletion of their data;
  • withdraw consent to processing;
  • appeal the Operator's actions or omissions to Roskomnadzor or in court.

The right to deletion does not extend to data already recorded in a public blockchain: such records are outside the Operator's control and cannot be erased or amended. Nor does it extend to data the Operator is required by law to retain, including invoices and payment records.

To exercise any right, contact support@encoresoft.io. The Operator responds within the time limits set by applicable law.

8. Consent

Where processing is based on consent, the user gives it at sign-up or when submitting a waitlist application, as a separate consent, apart from this Policy and the Public Offer.

9. Children

The Service is not directed to, and the Operator does not knowingly collect data from, persons under 18.

10. Security

The Operator applies reasonable organizational and technical measures to protect personal data against unauthorized access, alteration, disclosure or destruction.

11. Changes

This Policy may be updated. The current text is always published on the website.

12. Governing law

This Policy is governed by the law of the Russian Federation.

Contact: support@encoresoft.io · Full operator details: see the Public Offer.

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