Privacy Policy

Last Updated On: 17 September 2022;mobile application , the Lysto APIs and any other microsite, hyperlink, or URL (collectively, “Website”) as may be created or operated by Digitible Pte. Ltd., a company incorporated under the laws of Singapore, and having its registered office at 20, Bendemeer Road, #03-12 BS Bendemeer Centre, Singapore – 339 914 (“Lysto”). Lysto, through the Website, provides certain services (collectively, “Services”) to its users as per the Terms of Use, available at

For the purposes of this privacy policy (“Policy”), “we”, “our” and “us” shall mean Lysto and “you” and “your”, shall mean you as a User of the Website. If you are using/viewing the Website on behalf of a company or any other entity, then “you” shall include you and that entity, and you represent and warrant that: (a) you are an authorized representative of the entity with the authority to bind the entity to this Policy; and (b) you agree to this Policy on the entity’s behalf.

Capitalised terms used in this Policy but not defined herein shall have the same meaning as defined in the Terms of Use.

This Policy covers our policies and practices regarding collection, use and disclosure of personal information we receive about you when you use or otherwise interact with us on the Website and otherwise, in connection with the Services. This Policy does not apply to websites or the practices of the companies that Lysto does not own or control, or to individuals that Lysto does not employ or manage, such as the third party links on the Website and the third parties who publish their content on the Website.

By communicating or engaging with the Website or using the Services provided, you acknowledge that you have read and understood this Policy and agree and consent to the use, processing, disclosure and transfer of your personal data by Lysto in the manner described under this Policy. Any email Lysto sends to you will contain an automated unsubscribe link so that you can opt-out of the mailing list. You can also withdraw your consent by written notice to our Data Protection Officer.


1.1 “Personal Data” means data that allows someone to identify you individually, including, for example, social media handle(s), as well as any other non-public information about you that is associated with or linked to any of the foregoing.

1.2 “Anonymous Data” means data that is aggregated and de-identified, i.e., it is not associated with or linked to your Personal Data. Anonymous Data does not, by itself, permit the identification of individual persons.

1.3 In the course of providing you with the Services, we collect Personal Data and Anonymous Data in the manner set out herein below.

1.3.1 Information You Provide Us. When you use our Website or contact us, we may collect Personal Data from you, such as email address, first and last name, user name, and other information you provide. We also collect your blockchain address, which may become associated with Personal Data when you use our Website. If you provide us with feedback or contact us, we will collect your name and contact information, as well as any other content included in the message. We may also collect Personal Data at other points where you voluntarily provide it or where we state that Personal Data is being collected.

1.3.2 Information Collected via Technology. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: Information collected by our servers: to provide our Service and make it more useful to you, we (or a third party service provider authorised by us) collect information from you, including, but not limited to, your browser type, operating system, internet protocol address, mobile device ID, blockchain address, wallet type, and date/time stamps. Log files: we gather certain information automatically and store it in log files. This information includes internet protocol address, browser type, identity of the internet service provider (“ISP”), referring/exit pages, operating system, date/time stamps, and clickstream data. We use this information to analyze trends, administer the Service, track a user’s movements around the Website, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Website, it will recognize you and the information can be used to personalize your experience. Cookies: we use cookies to collect information in order to analyze how users interact with our Website, make improvements to our product quality, and provide users with a tailormade experience. We may use both session cookies (which expires once you close your web browser) and persistent cookies (which stay on your computer until you delete them). Web beacons: web beacons allow us to analyze how users find our Service. This aids us in making the Website more useful to you and to tailor your experience with us in order to meet your particular interests and needs. Do not track signals: Our systems do not currently recognize “do not track” signals or other mechanisms that might enable Users to opt out of tracking on our site. Analytics services: In addition to the tracking technologies we place, like cookies and web beacons, other companies may set their own cookies or similar tools when you visit our Website. This includes third-party analytics services (“Analytics Services”) that we engage to help analyze how users use the Website. The information generated by the cookies or other technologies about your use of our Website (“Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity, which we may receive on an individual or aggregate basis. We use the information we get from Analytics Services to improve our Service. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ terms of use and privacy policy. By using our Website, you expressly consent to the processing of data about you by Analytics Services in the manner and for the foregoing purposes.

1.3.3 Information Collected from Third-Party Companies. We may receive Personal and/or Anonymous Data about you from companies that offer their products and/or services for use in conjunction with our Service or whose products and/or services may be linked from our Website. For example, third-party wallet providers provide us with your blockchain address and certain other information you choose to share with those wallets providers. We may add this to the data we have already collected from or about you through our Website.

1.3.4 Public Information Observed from Blockchains. We collect data from activity that is publicly visible and/or accessible on blockchains. This may include but not be limited to blockchain addresses, information regarding purchases, minting of NFTs, personal gaming data and personal gaming profiles, which may then be associated with other data you have provided to us.


2.1 We process your Personal Data to run our business, provide the Service, personalize your experience on the Website, and improve the Service. Specifically, we use your Personal Data to:

2.1.1 facilitate the creation and securing of your account;

2.1.2 identify you as a User in our system;

2.1.3 improve the administration of our Service and quality of experience when you interact with our Website, including, but not limited to, by analyzing how you and other users find and interact with the Website;

2.1.4 provide customer support and respond to your requests, complaints and inquiries;

2.1.5 investigate and address conduct that may violate our Terms of Use;

2.1.6 detect, prevent, and address fraud, violations of our terms or policies, and/or other harmful or unlawful activity;

2.1.7 send you administrative notifications, such as security, support, and maintenance advisories;

2.1.8 send you notifications related to actions on the Website, including notifications of offers;

2.1.9 send you newsletters, promotional materials, and other notices related to our Website or third parties' goods and services;

2.1.10 respond to your inquiries related to any opportunities or other requests;

2.1.11 comply with applicable laws, cooperate with investigations by law enforcement or other authorities of suspected violations of law, and/or to pursue or defend against legal threats and/or claims; and

2.1.12 act in any other way we may describe when you provide Personal Data.

2.2 We may create Anonymous Data records from Personal Data. We use this Anonymous Data to analyze request and usage patterns so that we may improve our Services and enhance Service navigation. We reserve the right to use Anonymous Data for any lawful purpose and to disclose Anonymous Data to third parties without restriction.


3.1 We disclose your Personal Data as described below and as described elsewhere in this Policy:

3.1.1 Third Party Service Providers. We may share your Personal Data with third party service providers to: (a) provide technical infrastructure services; (b) conduct quality assurance testing; (c) analyze how our Website is used; (d) prevent, detect, and respond to unauthorized activities; provide technical and customer support; and/or (e) to provide other support to us in connection with the Services.

3.1.2 Affiliates. We may share some or all of your Personal Data with our holding company, subsidiaries, joint ventures, or other companies under our common control (“Affiliates”), in which case we will require our Affiliates to honor this Policy.

3.1.3 Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Policy.

3.1.4 Legal Rights. Regardless of any choices you make regarding your Personal Data (as described in Clause 7 below), Lysto may disclose Personal Data if it believes in good faith that such disclosure is necessary: (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas, warrants, or other legal process served on Lysto; (c) to protect or defend the rights or property of Lysto or users of the Website; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Policy, or our Terms of Use.

3.1.5 Other Disclosures. We may also disclose your Personal Data: (a) to fulfill the purpose for which you provide it; (b) for any other purpose disclosed by us when you provide it; or (b) with your prior consent.


Our Website may contain links to third-party websites. When you click on any such link to another website or location, you will leave our Website and go to another site, and another entity may collect Personal Data and other data from you. We have no control over, do not review, and cannot be responsible for these third-party websites or their content. Please be aware that the terms of this Policy do not apply to these third-party websites or their content, or to any collection of your Personal Data after you click on links to such third-party websites. We encourage you to read the privacy policies of every website you visit. Any links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.


To avail of our Services, you must use a ‘MetaMask’ wallet which allows you to engage in transactions on public blockchains. Your interactions with any third-party wallet provider are governed by the applicable terms of service and privacy policy of that third party.


6.1 You have several choices regarding the use of information on our Website:

6.1.1 Communication. We may periodically send you newsletters, emails and/or messages to your discord id (collectively, “Communication”), that directly promote the use of our Website or third parties’ goods and services. When you receive such Communication, you may indicate a preference to stop receiving the same by following the unsubscribe instructions provided in the Communication you receive or through the Notifications preferences in your settings page. Despite these preferences, we may send you necessary transactional or service-related informational Communication which would require your attention.

6.1.2 If you decide at any time that you no longer wish to accept Cookies from our Website for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Website or all the functionalities of the Website.


7.1 You can view, access, edit, or delete your Personal Data for certain aspects of the Website via your settings page. You may also have certain additional rights:

7.1.1 If you are a user in the European Economic Area or United Kingdom, you have certain rights under the respective European and UK General Data Protection Regulations (“GDPR”). These include the right to: (i) request access and obtain a copy of your personal data; (ii) request rectification or erasure; (iii) object to or restrict the processing of your personal data; and (iv) request portability of your personal data. Additionally, if we have collected and processed your Personal Data with your consent, you have the right to withdraw your consent at any time.

7.1.2 If you are a California resident, you have certain rights under the California Consumer Privacy Act (“CCPA”). These include the right to (i) request access to, details regarding, and a copy of the Personal Data we have collected about you and/or shared with third parties; (ii) request deletion of the Personal Data that we have collected about you; and (iii) the right to opt-out of sale of your Personal Data. As the terms are defined under the CCPA, we do not “sell” your personal information, including the Personal Data.

7.1.3 If you wish to exercise your rights under the GDPR, CCPA, or other applicable data protection or privacy laws, please contact us at the address provided in Section 13 below, specify your request, and reference the applicable law. We may ask you to verify your identity, or ask for more information about your request. We will consider and act upon any such request in accordance with applicable law. We will not discriminate against you for exercising any of these rights.

7.1.4 Notwithstanding the above, we cannot edit or delete any information that is stored on a blockchain as we do not have custody or control over any blockchains. The information stored on the blockchain may include purchases, sales, and transfers related to your blockchain address and NFTs held at that address.


We may retain your Personal Data as long as you continue to use the Website, have an Account with us, or for as long as is necessary to fulfill the purposes outlined in this Policy. We may continue to retain your Personal Data even after you deactivate your Account and/or cease to use the Website if such retention is reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our Terms of Use or other agreements, and/or protect our legitimate interests. Where your Personal Data is no longer required for these purposes, we will delete it.


We care about the security of your information and use physical, administrative, and technological safeguards to preserve the integrity and security of information collected through our Website and/or while providing the Services. However, no security system is impenetrable, and we cannot guarantee the security of our systems. In the event that any information under our custody and control is compromised as a result of a breach of security, we will take steps to investigate and remediate the situation and, in accordance with applicable laws and regulations, notify those individuals whose information may have been compromised. You are responsible for the security of your digital wallet, and we urge you to take steps to ensure it is and remains secure. If you discover an issue related to your wallet, please contact your wallet provider.


Our Terms of Use require all Users to be at least 18 years old. Users who are under 18 years old may use a parent or guardian’s Account, but only with the involvement of the Account holder. If a User under 18 submits Personal Data to Lysto (without the supervision of a parent or guardian) and we learn that the Personal Data is the information of a User under 18, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a user under 18, please contact us by using the address indicated in Section 13 below.


We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the Personal Data Protection Act, 2012.


12.1 This Clause only applies to you if we process your data while you are in the EEA. It explains that you have a number of rights in relation to your personal data under the EU General Data Protection Regulation 2016/679 (“GDPR”), the Data Protection Act, 2018, UK GDPR or any other applicable data protection laws following Brexit. However, the additional rights only apply when we process your personal data while you reside within the EEA or UK, as the case may be. If the additional rights do apply, you have the right to request that we:

12.1.1 provide you with a copy of the information we hold about you;

12.1.2 update any of your personal data if it is inaccurate or out of date;

12.1.3 delete the personal data we hold about you - if you are using our Website, and you ask us to delete personal data we hold about you then we may be unable to continue providing access to our Website to you;

12.1.4 restrict the way in which we process your personal data;

12.1.5 stop processing your personal data if you have valid objections to such processing; and

12.1.6 transfer your personal data to a third party.

12.2 In providing Services to you, you understand that we may transfer your information to different locations around the world. For users resident in the EEA or UK, where your personal data is transferred from the EEA or UK to a recipient outside the EEA or UK to a third country not recognized as providing an adequate level of protection for personal data, such transfer shall be covered by a framework recognized by the relevant authorities or courts as providing an adequate level of protection for personal data, including, but not limited to, Standard Contractual Clauses (as formulated under the European Commission's decision of February 5, 2010 for the transfer of personal data to processors established in third countries, also used under the UK GDPR), the terms of which shall be incorporated by reference.


This Policy may be updated from time to time for any reason. We will notify you of any changes to our Policy by posting the new Policy at []. The date the Policy was last revised is identified at the end of this Policy. You are responsible for periodically visiting our Website and this Policy to check for any changes.


14.1 If you have any questions or concerns or complaints about our Policy or our data collection or processing practices, or if you want to report any security violations to us, please get in touch with our data protection officer as per the contact information set out below.

NAME: Sadiq Ahamed

ADDRESS: 20, Bendemeer Road, #03-12 BS Bendemeer Centre, Singapore -- 339 914


This Policy was last updated on September 17, 2022