Privacy Policy

Last updated:  September 14th, 2026

BITSPIRE ECOSYSTEM — PRIVACY POLICY & DATA PROTECTION NOTICE

Operating Company: Bitspire LLC (Georgia)

Official Domains: https://bitspire.eu | https://landbits.io | https://surprisemap.com

1. INTRODUCTION & DATA CONTROLLER IDENTIFICATION

1.1 Data Controller Identity: This Privacy Policy and Data Protection Notice (“Privacy Policy”) sets forth the policies and procedures of Bitspire LLC (“Bitspire,” “Company,” “we,” “our,” or “us”) regarding the collection, processing, use, storage, disclosure, and protection of personal data across our cloud infrastructure, self-service SaaS portals, webshops, mobile applications, and automated software delivery platforms.

1.2 Legal Compliance Standard: Bitspire LLC processes all personal data strictly in accordance with applicable data protection laws, including the Law of Georgia on Personal Data Protection, the EU General Data Protection Regulation (GDPR – Regulation (EU) 2016/679), and relevant international privacy frameworks.

1.3 Corporate Identity & Contact Information:

  • Legal Entity: Bitspire LLC

  • Company Identification Number: 404789172

  • Registered Corporate Address: 12 Nikoloz Baratashvili Street / 2 Sanapiro Street, Krtsanisi District, Tbilisi 0105, Georgia

  • Contact Email: office.bitspire@gmail.com

  • Contact Phone: +995 599564870

  • Data Protection Officer Email: office.bitspire@gmail.com

2. SCOPE OF POLICY & TWO-PILLAR ECOSYSTEM STRUCTURE

2.1 System-Wide Scope: This Privacy Policy applies to all website visitors, registered account holders, business clients, Master Licensees, advertisers, and software end-users interacting with the Bitspire SaaS Ecosystem.

2.2 Alignment with Commercial Product Pillars: Data processing activities are organized around Bitspire LLC’s two distinct commercial product categories:

  • PILLAR I — LandBits Virtual Play Area Grid Units (landbits.io): Standalone digital software coordinate units (LandUnits/LandTiles) used to assign 10×10 meter play area grid allocations on the 1:1 scale mapping engine. Processing includes coordinate assignment logging, account ledgers, and KYC verification for variable ad performance fee distributions.

  • PILLAR II — SurpriseMap Master Licenses (surprisemap.com / bitspire.eu): Specialized B2B SaaS operational rights granting business entities (“Master Licensees”) regional operating authority over location-based ad media across designated geographical boundaries. Processing includes business verification (KYB), corporate invoicing, Admin Panel telemetry, and central protocol API execution.

2.3 Exclusion of Third-Party Links: This Privacy Policy does not apply to third-party websites, external mobile applications, or payment processing environments linked to or integrated with our platforms, which maintain independent privacy notices.

3. CATEGORIES OF PERSONAL DATA WE COLLECT

Bitspire LLC collects personal data strictly necessary to execute transactions, deliver automated software products, fulfill legal and tax duties, and defend system security.

3.1. Account & Registration Data Provided Directly

  • Individual Accounts (LandBits & Users): Full legal name, username/pseudonym, email address, account password hashes, phone number, billing address, country of residence, and communication preferences.

  • Corporate Accounts (Master Licensees & Advertisers): Entity legal name, corporate registration number, tax identification / VAT number, registered business address, authorized corporate representative name, business email, and billing records.

3.2. Financial & Transactional Data

  • Billing & Order Records: Transaction identification numbers, order history, package selection (Silver, Gold, Diamond), Master License Fee schedules, invoice receipts, and currency logs (processed strictly in United States Dollars – USD).

  • Payment Security Disclosure: Card transactions initiated via bitspire.eu are executed through PCI-DSS Level 1 compliant Payment Service Providers (PSPs) or acquiring banks. Bitspire LLC does NOT directly process or store full Payment Card Numbers (PAN), CVV/CVC security codes, or PIN credentials on its primary servers. Payments are processed via encrypted, tokenized payment frames.

3.3. Identity Verification Data (KYC for B2C / KYB for B2B)

To fulfill Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and commercial tax regulations:

  • B2C KYC Data (LandBits Distributions): Government-issued photo identification (passport, national ID card, or driver’s license), proof of residential address (utility bill or bank statement issued within 3 months), tax identification numbers, and automated biometric liveness verification records collected prior to executing variable ad distribution payouts.

  • B2B KYB Data (Master Licensees): Certificates of Incorporation, tax residency certificates, Articles of Association, official corporate registry extracts, and identity verification documents for Ultimate Beneficial Owners (UBOs) holding 25% or more equity.

3.4. Geolocation & Interactive Map Data

  • Coordinate Mapping: Static 10×10 meter software coordinates (LandUnits) selected, assigned, or owned on the landbits.io interface.

  • Mobile Geolocation Telemetry: Real-time device GPS coordinates, Wi-Fi positioning data, and IP-derived location data transmitted via the SurpriseMap mobile application strictly when necessary to detect user proximity to campaign markers, unlock promotional offers, or verify real-world coordinate interactions.

3.5. Automatically Collected Technical & Audit Data

When accessing Bitspire web portals or API endpoints, our cloud servers automatically log technical session markers:

  • IP addresses, device hardware identifiers (IMEI/UUID), browser type/version, operating system details, and mobile network markers;

  • Exact UTC/CET timestamps recording page views, API calls, login sessions, checkout approvals, and database allocation triggers;

  • Security audit markers tracking bot traffic, failed authorization attempts, and API rate-limiting events.

4. LAWFUL BASES AND PURPOSES OF PROCESSING

Bitspire LLC processes personal data strictly under valid legal grounds established by Article 6 of the GDPR and relevant provisions of Georgian Law:

4.1. Performance of a Contract (GDPR Art. 6(1)(b))

Processing is necessary to fulfill our contractual commitments under the Master Terms of Use, LandBits Package orders, and Master License Agreements, including:

  • Generating software license keys, activating Admin Panel credentials, and provisioning landbits.io database credit ledgers;

  • Executing automated API dispatches and managing recurring SaaS billing;

  • Facilitating the settlement of variable ad performance fee distributions and regional revenue allocations.

4.2. Legal Obligation (GDPR Art. 6(1)(c))

Processing is necessary to comply with legal, tax, and regulatory mandates imposed on Bitspire LLC, including:

  • Conducting mandatory KYC/KYB identity verification under international Anti-Money Laundering (AML) standards prior to financial payouts;

  • Maintaining corporate accounting ledgers, transaction records, and tax invoices for statutory audit periods;

  • Complying with law enforcement disclosure orders and international sanction screening lists (OFAC/EU/UN).

4.3. Legitimate Interests & Chargeback Defense (GDPR Art. 6(1)(f))

Processing is necessary for the legitimate commercial interests pursued by Bitspire LLC, provided such interests are not overridden by user privacy rights, including:

  • Maintaining cloud infrastructure uptime, API security, tenant isolation, and web application firewalls;

  • Logging immutable, millisecond-accurate audit trails (IP addresses, server dispatch tokens, database credit logs) to prove digital software delivery and defend against fraudulent credit card chargebacks, payment disputes, or merchant recall claims;

  • Detecting and preventing platform abuse, GPS spoofing, bot farming, and unauthorized coordinate manipulation.

4.4. Consent (GDPR Art. 6(1)(a))

Processing is based on your explicit consent where legally required, such as opting into non-essential analytical cookies, direct marketing communications, or precise background geolocation tracking within mobile applications. Consent may be withdrawn at any time via user settings.

5. CONTROLLER VS. PROCESSOR ROLES IN MASTER LICENSING (PILLAR II)

5.1 Master Licensee as Independent Data Controller: For all localized commercial operations, local advertiser onboarding, local merchant CRM databases, and territory-specific marketing campaigns executed within a licensed Territory:

  • The Master Licensee acts as an independent Data Controller responsible for complying with applicable local data protection statutes (including local consent collection, privacy notices, and local regulatory filings);

  • The Master Licensee is solely responsible for ensuring that all advertiser content and local promotional campaigns comply with territorial privacy rules.

5.2 Bitspire LLC as Data Processor: In providing the central cloud infrastructure, Admin Panel systems, backend APIs, and global map registries for Pillar II, Bitspire LLC acts as a Data Processor executing technical tasks on behalf of the Master Licensee, governed by standard Data Processing Agreements (DPAs) incorporated into Master License workflows.

6. PERMANENT AUDIT LOGS, CHARGEBACK DEFENSE & DATA DISCLOSURE TO BANKS

6.1 Immutable Proof of Fulfillment: Due to the immediate electronic delivery and non-returnable nature of our digital software products, Bitspire LLC maintains real-time server database ledgers capturing:

  • User account registration IDs, verified billing names, and account email addresses;

  • Exact UTC/CET checkout timestamps and payment gateway response codes;

  • Purchaser IP addresses, device session tokens, and geolocation markers recorded during checkout on bitspire.eu;

  • Real-time database audit logs proving the exact millisecond when LandUnits or Master License credentials were credited to the purchaser’s ledger;

  • Subsequent post-delivery login logs and API session records.

6.2 DISCLOSURE TO PAYMENT SERVICE PROVIDERS & COURTS:

  • Pursuant to GDPR Article 6(1)(f) (Legitimate Interest) and Section B3 of Annex B (Master Terms of Use), Bitspire LLC explicitly reserves the right to disclose these server audit trails, checkout IP records, electronic receipts, and signed checkout acceptance logs to:

    1. Acquiring Banks & Payment Service Providers (PSPs);

    2. Credit Card Networks (Visa, Mastercard, American Express);

    3. Merchant Fraud Prevention Agencies & Credit Rating Bureaus;

    4. Competent Judicial Courts and Arbitral Tribunals in Tbilisi, Georgia, or local jurisdictions.

  • Disclosures are executed strictly for the purpose of defending Bitspire LLC against unauthorized chargebacks, fraudulent “item not received” claims, civil billing disputes, or criminal payment processor investigations.

7. PUBLIC DATA VISIBILITY ON THE INTERACTIVE MAP ENGINE

7.1 Public Grid Registry: By assigning LandUnits on the interactive landbits.io map interface or placing campaign markers via SurpriseMap, you acknowledge that certain non-sensitive software parameters are publicly displayed across the Ecosystem, including:

  • Publicly assigned 10×10 meter coordinate locations (LandTiles/LandUnits);

  • Brand logos, promotional media, custom coupons, and public links attached to coordinates by the coordinate owner or Master Licensee;

  • Public usernames, leaderboards, community activity badges, and non-sensitive engagement metrics.

7.2 Permanent Registry Integrity: Publicly assigned coordinate allocations remain anchored to system database ledgers to preserve global map registry integrity, protocol transparency, and automated LandTile Owner Share payout execution.

8. INTERNATIONAL DATA TRANSFERS & CLOUD INFRASTRUCTURE

8.1 Global Cloud Processing: Bitspire LLC operates internationally. Personal data collected across our portals is stored and processed on secure cloud server infrastructure located in the European Economic Area (EEA), Georgia, and enterprise cloud vendor data centers (e.g., Amazon Web Services, Cloudflare, Google Cloud).

8.2 Transfer Safeguards: Where personal data originating in the EEA or UK is transferred to Georgia or other non-EEA jurisdictions, Bitspire LLC ensures adequate protection through:

  • European Commission approved Standard Contractual Clauses (SCCs) embedded in vendor agreements;

  • Statutory data protection safeguards enforced under the Law of Georgia on Personal Data Protection;

  • Enterprise-grade cryptographic encryption for data in transit and at rest.

9. DATA RETENTION SCHEDULE

Bitspire LLC retains personal data strictly for the duration necessary to fulfill the operational, tax, and legal purposes set forth in this Policy, in accordance with the following schedule:

Data Category Purpose & Description Statutory / Operational Retention Period
Active Account Records User profiles, account credentials, LandUnit assignment ledgers, Master License settings. Retained for the active duration of the account plus 2 years following account closure.
Financial & Tax Records Invoices, payment receipts, bitspire.eu order logs, corporate wire records. 6 years from transaction date to comply with Georgian tax codes and corporate accounting laws.
KYC / AML Compliance Files Government photo IDs, proof of address, KYB corporate files, UBO declarations, payout audit logs. 5 to 7 years following account closure or payout execution in compliance with global AML mandates.
Transaction Audit Logs & IP Data Server-side checkout logs, IP addresses, database credit timestamps, payment authorization tokens. 7 years from transaction date to ensure comprehensive chargeback defense and card network compliance.
Security & System Telemetry Web server access logs, firewall logs, bot detection markers, failed API calls. Up to 12 months, after which data is automatically purged or anonymized.

10. TECHNICAL, ORGANIZATIONAL & DATABASE SECURITY MEASURES

Bitspire LLC implements enterprise-grade technical and organizational security controls to protect personal data against unauthorized access, loss, alteration, or disclosure:

  • Encryption in Transit: All web traffic, payment checkouts, and API communications are encrypted using Transport Layer Security (TLS 1.3 / HTTPS) protocols;

  • Encryption at Rest: Sensitive database records, identity verification files, and system credentials are encrypted using AES-256 standards;

  • Access Control & Tenant Isolation: Strict Role-Based Access Control (RBAC) and Multi-Factor Authentication (MFA) restrict employee access to personal data under the principle of least privilege;

  • Network Defense: Deployment of Web Application Firewalls (WAF), automated DDoS mitigation tools, intrusion detection systems, and regular vulnerability scanning;

  • Payment Isolation: Complete isolation of payment card processing frames to licensed PCI-DSS Level 1 gateways.

11. YOUR DATA PROTECTION RIGHTS & STATUTORY EXCEPTIONS

Under applicable data protection laws (including GDPR and Georgian privacy statutes), you possess the following data rights, subject to statutory limitations:

  1. Right of Access: Request confirmation of whether your personal data is processed and receive a copy of your personal data records;

  2. Right to Rectification: Request immediate correction of inaccurate or incomplete profile details;

  3. Right to Erasure (“Right to be Forgotten”): Request the deletion of your personal data. Statutory Exception: The right to erasure does NOT apply to data that Bitspire LLC is legally mandated to retain, including tax invoices, AML audit records, active map coordinate assignments, or permanent transaction audit logs required for chargeback defense under Section 6;

  4. Right to Restriction of Processing: Request temporary restriction of data processing during legal dispute reviews;

  5. Right to Data Portability: Receive your account data in a structured, commonly used, and machine-readable format;

  6. Right to Object: Object to data processing based on legitimate interests or direct marketing.

Exercising Rights: To submit a formal data privacy request, contact our Data Protection Officer at office.bitspire@gmail.com. You also maintain the statutory right to lodge a complaint with the Personal Data Protection Service of Georgia or your local European Data Protection Authority.

12. CHILDREN’S PRIVACY MANDATE (18+ ONLY)

Our software platforms, LandBits coordinate tools, and B2B Master Licenses are strictly designed and intended for business clients and natural persons aged eighteen (18) years or older. Bitspire LLC does not knowingly collect or solicit personal data from minors under 18. If we discover that an account has been created by a minor, the account will be immediately terminated, and associated data purged from active systems.

13. UPDATES TO THIS PRIVACY POLICY

Bitspire LLC reserves the right to update or modify this Privacy Policy at any time to reflect cloud architecture upgrades, new software features, regulatory changes, or updated payment gateway procedures. Material updates will be notified via email or prominent system banners across official domains with a revised “Last Updated” date.

14. COMPLIANCE CONTACT DETAILS

For questions, data protection requests, or compliance inquiries regarding this Privacy Policy, please contact:

Bitspire LLC — Data Protection Office

Company ID No: 404789172

Address: 12 Nikoloz Baratashvili Street / 2 Sanapiro Street, Krtsanisi District, Tbilisi 0105, Georgia

Contact Email: office.bitspire@gmail.com

Contact Phone: +995 599564870

Official Domains: bitspire.eu | landbits.io | surprisemap.com