Privacy Policy
Last Updated: 1 December 2025
Governing Law: Republic of Panama
Applicable Laws:
Law 81 of 2019 (Ley de Protección de Datos Personales)
Executive Decree 285 of 2021 (Regulation of Law 81)
Law 51 of 2008 (Electronic Commerce, Documents and Signatures)
Law 32 of 2011 (Corporate governance + electronic records provisions)
1. Introduction
TopStrike ("we", "our", "us") is a Panama-incorporated company providing a blockchain-based fantasy football and trading game. This Privacy Policy explains how we process personal data when you access the TopStrike platform ("Service").
This Policy is drafted in accordance with Law 81 of 2019, Articles 1–4 (scope), and Decree 285, Articles 1–3.
2. Who Is Responsible for Your Data
TopStrike Corp
Registered in the Republic of Panama
PH The Century Tower, Office 317 Betania, Vía Ricardo J. Alfaro 07095 Panama City, Republic of Panama
We act as the "Responsible Party" ("Responsable") under Law 81, Article 3(9).
3. What Data We Collect
We collect only what is necessary to operate the Service.
3.1 Data You Give Us
Email address (optional)
Support messages
(Compliant with Law 81, Article 6 – Data Minimisation.)
3.2 Data Collected Automatically
Public blockchain wallet address
Smart contract interactions & on-chain activity
IP address (security, fraud prevention, geoblocking)
Browser/device type
Basic analytics (non-identifiable). We do not engage in automated profiling or behavioural advertising.
Server logs: URL visited, referrer, device host, timestamp
(As recognised under Decree 285, Article 7 – Legitimate Interest)
3.3 Data We Do NOT Collect
Passwords
Financial / debit / credit card details
National IDs or proof of identity (unless required for compliance)
Behavioural advertising identifiers
Sensitive data (Law 81, Article 4(6))
3.4 Children
The Service is strictly 18+. We do not knowingly process data of minors under Law 81, Article 5.
4. How We Use Personal Data
In line with Law 81, Articles 6–7, we use your data for:
Access to the platform
Gameplay and smart-contract interactions
Distribution of ETH rewards (prize pool payouts)
Security, fraud prevention & abuse monitoring
Enforcing regional restrictions
Customer support
Improving platform performance
We never sell or rent your data.
5. Legal Bases for Processing
We rely on the lawful bases permitted under Law 81, Article 7, specifically:
Consent (cookie acceptance, optional email)
Execution of a contractual relationship (providing the Service)
Legitimate interest (security, preventing fraud, platform integrity)
Legal obligation (if AML/KYC is triggered during prize payout events)
6. Cookies & Tracking
As permitted by Law 51 of 2008 on electronic records and signatures, we use cookies for:
Security
Session management
Basic analytics
No targeted advertising cookies are used.
7. Data Sharing
Under Law 81, Articles 8–9, we may share data with:
7.1 Service Providers (Processors)
Hosting/cloud services
Security & anti-abuse tools
Analytics providers
Email support platforms
Each processor acts under data processing agreements (DPAs) per Decree 285, Article 25.
7.2 Legal Obligations
We may disclose data to:
Courts
Regulators
Law enforcement
When required by Law 81, Article 22.
7.3 Blockchain
Wallet addresses and transactions are public by design and not controlled by us. This is inherent to blockchain technology.
8. International Transfers
Data may be processed outside Panama. In accordance with Law 81, Articles 33–34, we ensure:
adequacy standards recognised by ANTAI, or
standard contractual clauses (SCCs) under Decree 285, Article 44
9. How Long We Keep Data
We retain data only as long as needed for:
operating the Service
compliance with obligations
resolving disputes
enforcing agreements
This follows Law 81, Article 29 – Proportional Retention.
10. Your Rights Under Panama Law
Under Law 81, Articles 14–15, you have:
✔ Right of Access
✔ Right to Rectification
✔ Right to Erasure
✔ Right to Object
✔ Right to Data Portability
✔ Right to Restrict Processing
✔ Right not to be subject to automated decisions
To exercise these rights:
(We may ask you to sign a message from your wallet to verify identity.)
11. GDPR Supplemental Rights (EEA Users Only)
For users in the EEA, you may have additional rights under GDPR Articles 12–23, including:
Access
Rectification
Erasure
Objection
Portability
Restriction
This supplemental section does not change the governing law of this Policy. For EEA users, personal data may be transferred outside the EEA under appropriate safeguards, including Standard Contractual Clauses (SCCs).
12. Links to Third Parties
We are not responsible for the privacy practices of third-party websites.
13. Security
We apply the security principles required under Law 81, Article 28, including:
Encryption in transit
Access control
Monitoring for suspicious activity
Segregated environments
Data minimisation
14. Updates to This Policy
We may update this Policy to comply with:
changes in Applicable Law
product modifications
security improvements
Updates appear here with a revised "Last updated" date.
15. Contact
For any privacy queries or rights requests:
Subject: Privacy Request
16. Data Breach Notification
In the event of a data breach affecting personal data under our control, we will notify affected users and relevant authorities where required under applicable law.
17. Governing Law
This Privacy Policy is governed exclusively by:
Law 81 of 2019 on Personal Data Protection
Executive Decree 285 of 2021
Law 51 of 2008
Law 32 of 2011
Disputes relating to this Policy shall be resolved in accordance with the dispute resolution provisions set out in our Terms of Service.
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