Privacy Statement

Blueboard uses the information you provide to Blueboard or that Blueboard collects about you for different Purposes, as explained more in detail below.

• Compliance Purposes – to carry out obligations imposed by applicable laws, including the obligation to avoid money laundering, terrorist financing and fraud; to ensure the security of our Services; and to comply with the lawful inquiries and order of public authorities.
• Contractual Purposes – to enter into or perform our contracts with You, including providing the Services you have requested.
• Analytical Purposes – to gain a better understanding of the preferences of our customers and how they interact with our Services, and making improvements to them.
• Marketing Purposes – to send You marketing information about our products and services.

Here is further detail on which legal basis applies to which categories of data Blueboard processes:

• Contact Information – Used for contractual purposes (e.g., managing your account) and marketing purposes (e.g., sending you updates and promotions).
• Wallet Data – Used for contractual purposes (e.g., processing transactions), analytical purposes (e.g., understanding usage patterns), and compliance purposes (e.g., meeting legal requirements).
• Transactional Data – Used for contractual purposes (e.g., fulfilling services), analytical purposes (e.g., improving our platform), and compliance purposes (e.g., regulatory obligations).
• Technical Data – Used for contractual purposes (e.g., ensuring platform functionality), analytical purposes (e.g., optimizing performance), and marketing purposes (e.g., personalizing promotions).

Applicable law, including the GDPR, requires Blueboard to have a Legal basis for Processing Your Personal data. Blueboard Processes your Personal data under the following grounds:

• Compliance Purposes – GDPR Art. 6(1)(c), as relevant Processing is necessary for compliance with legal obligations stipulated in applicable laws to which Blueboard is subject.
• Contractual Purposes – GDPR Art. 6(1)(b), as relevant Processing is necessary for the performance or entry into a contract with You, including Blueboard Terms of Service. In other words, Personal data Processed for Contractual Purposes is necessary for us to deliver the Services to You.
• Analytical Purposes – GDPR Art. 6(1)(f), as we have legitimate interests to gain a better understanding of the preferences of our customers and how customers interact with the Services.
• Marketing Purposes – GDPR Art. 6(1)(f), as we have legitimate business interests to offer our customers additional services they may be interested in.

In general Blueboard does not retain Your data for longer than necessary to complete the Purpose for which it was collected.

• Contact Information, Technical Data, Personal Data, and Wallet Data are kept for a period of one year (for MiniPay), or two years.
• Transaction Data is retained for as long as a Crypto Assets or transaction is active, and for a period of one year (for MiniPay), or two years thereafter.

We process some data in order to promote and market our products and services. Some of this data comes directly from you, when you submit it to us for some specific purpose. For example, if you decide to provide feedback to Blueboard or participate in a promotional campaign, contest, or survey, organized by Blueboard or our partners on behalf of Blueboard, we may ask for information such as your name, age, phone number, email, or postal address. Depending on the nature of the campaign or contest, it may be necessary to share your data with third parties. When that applies, we will make it clear in the terms applicable to the campaign.
If you agree to receive marketing information from Blueboard via email, SMS, or push notifications, we may use third-party technology providers to deliver such messages to you. You can opt-out from marketing communication at any time in your user profile settings or directly from a marketing email you receive.
We may display in-app campaigns and promotions of Blueboard or Opera products, services or features through push-notifications. You may disable these notifications through your settings menu.
In general when we process data in the context of a promotional campaign, contest, or survey, we process your personal data on the basis that doing so is necessary to enable you to participate in the campaign. In some cases we may process data for marketing purposes based on your consent. In any case we will not retain your data any longer than necessary to fulfill the specific purpose for which it was processed to begin with. You can always control your preferences via the settings menu, and if you have other concerns you can reach us through this form.
Purpose: To promote our products and services.
Legal Basis: Varies by context as explained above - includes contractual grounds, or consent (in some cases).

In some circumstances Blueboard may share data (including Personal data) with third parties, including:

• Other members of the Opera Group. Blueboard is a member of the Opera Group that provides data Processing, marketing, and other support services to Blueboard.
• Third party services providers who help Blueboard to operate the Services. E.g. text message technology providers.
• Law enforcement agencies, if and when Blueboard is required to provide information to them in accordance with applicable law.
• Third party services providers who provide their own services inside Blueboard Services including on-ramp providers, off-ramp providers, swaps providers and Crypto Assets related services providers (no Personal data).
• Blockchain networks and related providers with whom you might complete a Crypto Assets transaction (no personal data).

MiniPay includes third-party technology or code, some of which may use your data in different ways. When such third-party technologies use previously collected data, they typically act as data processors for us. When they collect data on their own, they typically act as independent data controllers. For convenience, we have included links to their privacy policies below. Data controllers are marked with an asterisk.

• AppsFlyer
• Firebase Cloud Messaging
• WhatsApp

You have the right to make a request to access or delete any of your Personal data that Blueboard might possess. You can make a request via this online request form. You may be required to provide additional information to authenticate your request. In such a case we will process your email address for the purpose of your inquiry.
You also have the right to lodge a complaint with the appropriate authorities. You can contact the Data Protection Commission, the data protection supervisory authority of Ireland, or Datatilsynet, the Norwegian Data Protection Authority, through their websites.

Blueboard is very open about privacy and recognizes your trust as a great value. If you have any questions about this statement or any privacy issues in Blueboard applications or Services, feel free to contact our Data Protection Officer via this online request form in such a case we will process your email address for the purpose of your inquiry.