Legal Disclaimer

1. General Information

The information provided on the Gatsby Platform and all associated websites, applications, or documentation is for informational and educational purposes only. Nothing presented constitutes investment advice, financial promotion, or an offer to sell or solicit the purchase of any security, token, or financial instrument in any jurisdiction.

Gatsby does not conduct, operate, or promote speculative cryptocurrency trading, token launches, or investment products. Gatsby Gold (GG) functions strictly as a payment utility and digital settlement unit backed by physical gold reserves and corresponding cash or cash-equivalents held in regulated custody.

2. Regulatory Compliance

Gatsby complies with applicable anti-money laundering (AML), counter-terrorism financing (CTF), and know-your-customer (KYC) requirements, in accordance with standards established by recognized regulatory authorities and financial institutions.
Our services are not intended for and will not be made available to persons residing in jurisdictions that restrict the offering or use of digital asset-based payment systems.

Gatsby does not hold or manage user funds for investment purposes. All reserves are held by licensed custodians subject to audit and applicable financial reporting standards.

3. Risk Disclosure

Participation in digital asset-based transactions involves risk, including cybersecurity vulnerabilities, regulatory changes, technological errors, or network disruptions.
The value of digital representations of gold or any other asset may fluctuate depending on external market conditions. Users should seek independent professional advice before engaging with digital payment systems or assets.

Nothing on the Gatsby Platform should be interpreted as a guarantee of financial return, investment performance, or preservation of value.

4. No Investment or Securities Offering

Gatsby Gold (GG) is not a financial instrument, security, or investment product. It is a digital payment and settlement tool designed to facilitate microtransactions within approved digital ecosystems such as gaming, digital goods marketplaces, and creator platforms.
The use of Gatsby Gold does not grant ownership rights, dividend entitlements, or participation in revenue or governance beyond integrated payment functionality.

5. Jurisdictional Restrictions

Access to and use of Gatsby’s products and services may be restricted in certain jurisdictions. Users are under an obligation to ensure compliance with applicable local laws and regulations before engaging with the platform. Gatsby does not provide services in jurisdictions where such activity would require prior licensing, registration, or governmental approval that has not been obtained.

6. Limitation of Liability

To the fullest extent permitted by law, Gatsby, its affiliates, partners, officers, and developers disclaim all liability for losses, damages, or claims arising from:

  • Use or misuse of the Gatsby Platform or services

  • Any unauthorized access to digital wallets or data

  • Technological errors, service interruptions, or third-party integrations

  • Market fluctuations or regulatory actions affecting gold, stablecoins, or digital assets

Users assume full responsibility for actions taken based on platform information, tools, or communications.

7. Amendments

Gatsby reserves the right to update this disclaimer and related policies at any time to reflect evolving regulatory and operational standards. Revisions will be posted publicly, and continued use of the platform implies acceptance of the most recent terms.

In summary: Gatsby Platform offers compliant, gold-backed payment infrastructure, not speculative crypto or investment services. Users are encouraged to seek their own financial, tax, and legal counsel prior to participation.

Terms of Service

1. Acceptance of Terms

By accessing or using the Gatsby Platform, associated websites, applications, or any services operated by Gatsby Games FZCO (“Gatsby,” “we,” “our,” or “us”), you agree to be bound by these Terms of Service.
If you do not agree, you must not access or use our platform.

These Terms may be updated periodically. Your continued use of the platform after any update constitutes acceptance of the revised terms.

2. Eligibility

Users must be at least 18 years of age or the legal age of majority in their jurisdiction to create accounts or participate in gameplay and transactions.
Users are responsible for ensuring that accessing or using the platform does not violate local laws or regulations.

3. Description of Services

Gatsby provides a gold-backed settlement infrastructure for games, marketplaces, and developers to power microtransactions and digital asset ownership.
Gatsby is not a cryptocurrency exchange, brokerage, or investment platform.
All assets and payments are designed solely for use within approved game and digital commerce environments.

4. Accounts and Security

Users are responsible for maintaining the confidentiality of their account credentials. Any activity conducted through an account will be deemed to have been performed by the account owner.
Gatsby reserves the right to suspend, restrict, or terminate accounts found to be in violation of these Terms or applicable law.

5. Platform Conduct

Users agree not to:

  • Use cheats, bots, or exploits in games or digital services.

  • Manipulate transactions or prices within the platform.

  • Upload or share illegal, offensive, or harmful content.

  • Interfere with system operations, security measures, or third-party integrations.

Violation of these guidelines may result in account suspension and permanent removal from the platform.

6. Payments and Digital Assets

  • Gatsby Gold (GG) is a gold-backed settlement unit used for in-game and cross-platform payments.

  • GG is not a security or investment product and carries no ownership or dividend rights.

  • All transactions are processed through KYC/AML-compliant partners.

  • Gatsby does not guarantee the future value of any digital asset or payment unit.

Refunds, reversals, or offsets are handled according to applicable laws and app store frameworks.

7. Treasury Operations

Gatsby maintains a hybrid liquidity model consisting of gold reserves, cash, and short-term high-quality liquid assets.
All reserves are held by third-party licensed custodians and verified through independent audits.
The Treasury ensures liquidity for player payouts, developer settlements, and game ecosystem sustainability.

8. Intellectual Property

All trademarks, designs, visuals, software, and documentation associated with Gatsby are proprietary to Gatsby Games FZCO.
Users and developers receive a limited, revocable, non-transferable license to use Gatsby SDKs, APIs, and interfaces for authorized projects only.

9. Disclaimer of Warranties

Gatsby and its affiliates provide the platform “AS IS” and “AS AVAILABLE” without warranties of any kind.
We do not warrant that the platform will operate without interruption, error, or risk of unauthorized access.
All users assume full responsibility for the use of the Gatsby Platform and related technologies.

10. Limitation of Liability

To the fullest extent permitted by law, Gatsby Games FZCO, its officers, directors, employees, and affiliates will not be liable for:

  • Indirect, consequential, or incidental damages, including loss of data or profits.

  • Price fluctuations or regulatory changes affecting gold, digital assets, or virtual economies.

  • Third-party service outages or unauthorized account access.

Total liability under these terms will not exceed the amount paid to Gatsby within the preceding 12 months.

11. Indemnification

You agree to indemnify, defend, and hold harmless Gatsby Games FZCO, its affiliates, partners, officers, employees, licensors, and service providers from and against all claims, liabilities, damages, losses, costs, and expenses (including legal fees) arising from:

  • Your use or misuse of the platform or services.

  • Breach of these Terms or violation of any applicable law.

  • Misrepresentation, fraud, or misconduct related to digital assets or gameplay.

This clause survives the termination or suspension of your account and continues to protect Gatsby Games FZCO from all claims arising directly or indirectly from user actions.

12. Compliance and Legal Jurisdiction

These Terms are governed by the laws of the United Arab Emirates, with exclusive venue in the courts of Dubai International Financial Centre (DIFC).
Users agree to mandatory binding arbitration for disputes unless waived under governing law.

Users subject to foreign jurisdictions are responsible for compliance with their local laws regarding digital payments, digital asset ownership, and foreign exchange controls.

13. No Investment or Financial Advice

Information on the Gatsby Platform is not intended as investment advice or solicitation for investment.
Participation in digital asset ecosystems involves inherent risks and should be considered experimental. Users should seek independent legal or financial advice before engaging in any platform activity.

Privacy Policy

1. Introduction

Gatsby Games FZCO (“Gatsby,” “we,” “our,” or “us”) respects your privacy and is committed to collecting and processing personal data transparently, fairly, and in compliance with applicable data protection laws, including the UAE Personal Data Protection Law (PDPL) and applicable international frameworks.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you interact with the Gatsby Platform, our games, digital services, websites, APIs, and related applications (collectively, the “Services”).

Use of our Services signifies your agreement with this Privacy Policy.

2. Data We Collect

We may collect and process the following data categories to provide Services effectively:

A. Personal Identification Data:

  • Name, date of birth, nationality, and identification details (for KYC compliance).

  • Contact information, including email, phone number, and address.

B. Technical and Gameplay Data:

  • Login credentials, usage logs, IP address, device identifiers.

  • Game-related activity data, player preferences, and purchase history.

C. Financial and Transaction Data:

  • Payment and transaction details processed through verified third-party payment partners.

  • Settlement activity, platform wallet usage, and Gatsby Gold (GG) purchases.

D. Communication Data:

  • Inquiries through email, support chat, or social media.

  • Customer service interactions and responses.

We may also collect non-identifiable or aggregated data for analytics, product optimization, and service improvement.

3. Purpose of Data Processing

We collect and use your personal data to:

  • Deliver, operate, and enhance the Gatsby Platform and gaming experiences.

  • Process payments, payouts, and Treasury-linked transactions via regulated custodians.

  • Conduct identity verification (KYC/AML compliance).

  • Prevent fraud, unauthorized use, and compliance violations.

  • Support customer inquiries and optimize you experience.

  • Comply with legal obligations across relevant jurisdictions.

All processing is performed under a legitimate purpose in accordance with Articles 4–6 of the UAE PDPL.

4. Lawful Basis for Processing

We process your personal data on the following lawful grounds:

  • Performance of a contract (providing services you have requested).

  • Legal obligation (compliance with AML/KYC laws).

  • Legitimate interest (improving services, preventing abuse).

  • Consent (for optional marketing or communications, which can be withdrawn at any time).

5. Data Retention

We retain personal data only as long as necessary to fulfill service purposes or comply with regulatory requirements. Upon withdrawal of consent or account termination, data is securely archived or erased in line with PDPL data minimization principles.

6. Data Sharing and Transfers

We may share limited personal data with trusted third parties for lawful processing purposes:

  • Payment processors and verified custodians for transaction execution.

  • Regulated KYC/AML providers for identity verification.

  • Auditors, legal advisors, or government authorities where disclosure is legally required.

Cross-border data transfers:
If your data is transferred outside the UAE, Gatsby ensures equal or higher levels of protection through contractual safeguards and compliance with Articles 22–23 of the PDPL.

Gatsby Games FZCO does not sell, lease, or trade personal data under any circumstances.

7. Data Subject Rights

In accordance with the UAE PDPL, you have the following rights:

  • Access: Request a copy of your personal data we hold.

  • Rectification: Correct inaccurate or incomplete data.

  • Erasure: Request deletion where data is no longer required.

  • Restriction or Objection: Limit processing or object to direct marketing.

  • Portability: Request your data in a machine-readable format.

To exercise your rights, contact privacy@gatsbygames.com. Valid identification may be required.

8. Security and Data Protection Measures

We employ robust organizational and technical measures to protect data from unauthorized access, loss, or misuse, including:

  • Encryption of personal and financial data during transfer and storage.

  • Network and data segmentation for sensitive systems.

  • Multi-factor authentication for internal access control.

  • Regular audits and vulnerability assessments.

In the event of a data breach, we will notify affected individuals and relevant authorities promptly in accordance with PDPL Article 9.

9. Cookies and Tracking Technologies

Our platform uses cookies and tracking tools for basic functionality, analytics, and user experience enhancement.
Users can manage or disable cookies through browser settings while continuing to access core services.

10. Marketing and Communication

We only send marketing emails or promotional material with your consent.
You may withdraw consent or unsubscribe at any time using the provided opt-out link or by contacting us directly.

11. Third-Party Links

Our Services may include links to third-party platforms (such as payment processors, developers, or partners).
Gatsby Games FZCO is not responsible for the privacy practices of external websites or applications. We encourage you to review third-party privacy policies before interaction.

12. Children’s Privacy

Our services are intended for adults 18+. We do not knowingly collect data from minors.
If we become aware that a child has submitted personal data, we will securely delete it in accordance with applicable law.

13. Indemnification

You agree to indemnify and hold harmless Gatsby Games FZCO, its affiliates, officers, directors, employees, and service partners from any claims, liabilities, damages, or losses resulting from misuse of data, regulatory violations, or third-party interactions not under Gatsby’s direct control.

This clause ensures protection against claims arising from breaches caused by user negligence, third-party integrations, or unauthorized activity.

14. Updates to This Policy

Gatsby reserves the right to revise or update this Privacy Policy at any time in accordance with new regulatory, operational, or legal requirements.
Material updates will be communicated via notice on our website and updated effective dates.

Legal Disclaimer on Token Issuance and Custody

1. Corporate Independence

Gatsby Games FZCO (“Gatsby,” “we,” “our,” or “us”) is a registered game development and technology company, operating from the Dubai Multi Commodities Centre (DMCC) in the United Arab Emirates. Gatsby develops and maintains the Gatsby Platform, a gold-backed digital payment infrastructure for the gaming and interactive entertainment industries.

However, Gatsby Games FZCO is not and shall not be construed as the issuer, manager, or custodian of any token, digital asset, or financial instrument associated with the Gatsby ecosystem.

2. Token Issuance and Licensing

All licensed token issuance, including any form of digital unit referenced as “Gatsby Gold (GG)” or any related digital settlement asset, is managed exclusively by a separate, independently licensed entity (the “Token Issuer”) subject to applicable laws and financial regulatory oversight in its jurisdiction.

  • The Token Issuer is responsible for minting, redemption, and reserve verification activities related to any gold-backed or stable settlement asset.

  • All custody, compliance, anti-money laundering (AML), and counter-terrorism financing (CTF) obligations relating to tokenized assets are solely the responsibility of the Token Issuer and its regulated banking or vault partners.

  • Gatsby Games FZCO does not issue tokens, engage in token trading, or hold investor deposits or reserves on behalf of any third party.

3. No Investment or Financial Activity

Gatsby Games FZCO’s role is limited to providing platform infrastructure, developer tools, and software services that interface with digital assets through approved integrations.
Gatsby is not a financial institution, does not operate as a crypto exchange, virtual asset service provider (VASP), or money services business, and offers no investment, custody, or trading services.

Gatsby’s services are designed purely to support gaming economies and payments via technology tools and APIs.
Nothing in its materials or communication constitutes an invitation to invest, financial solicitation, or offering of securities or stablecoins to the public.

4. Risk and User Responsibility

Users and developers integrating or transacting with third-party issued tokens do so at their own risk and must comply with all applicable laws and regulatory requirements in their countries of operation.
Participants should ensure they are dealing with licensed custodians and issuers clearly identified in each relevant jurisdiction.

Gatsby Games FZCO shall not be held responsible for:

  • Token issuance, custody, redemption, or audit practices performed by third parties.

  • Fluctuations in asset value, system downtime, or compliance breaches of other ecosystem participants.

  • Any direct or indirect loss arising from reliance on token-issuer information, whitepapers, or promotional materials it did not publish or approve.

5. Indemnification

By using the Gatsby Platform, users agree to hold harmless and indemnify Gatsby Games FZCO, its subsidiaries, executives, employees, and affiliates from any claim, liability, or legal action linked directly or indirectly to:

  • The issuance, custody, or transfer of digital assets by third parties.

  • Token regulation, enforcement actions, or the misuse of third-party products integrated into the Gatsby ecosystem.

  • Loss, theft, or devaluation of any gold-backed or tokenized unit not directly controlled by Gatsby Games FZCO.

This indemnity survives termination of user accounts or cessation of platform use.

6. Regulatory Cooperation and Disclosures

Gatsby Games FZCO cooperates fully with local and international regulators and provides transparent disclosures to ensure that users understand the separation of functions between the Gatsby Platform and any Token Issuer.
All related entities adhere to UAE Federal Decree-Law No. 20 of 2018 on AML/CTF, Federal Decree-Law No. 45 of 2021 (PDPL), and Virtual Assets Regulatory Authority (VARA) compliance frameworks where applicable.

Summary:
Gatsby Games FZCO develops technology infrastructure but does not issue, manage, or guarantee any digital tokens.
All asset-backed token issuance, management, and redemption fall entirely under a separate licensed issuer operating under relevant financial supervision. Any token interactions on or through Gatsby’s technology occur independently of Gatsby Games FZCO.



Contact Information

For all privacy or compliance-related questions:

Gatsby Games FZCO
DMCC Uptown Tower, United Arab Emirates
Email: contact@gatsbygames.com