BigPirate – Privacy Notice

Introduction

RAFFLEFY LIMITED, with an address at 205 Christodoulou Chatzipavlou, Louloupis Court, 2nd Floor, Office 201 Limassol, Cyprus 3036 (“Company”, “we”, “our” or “us”) facilitates and operates the offering of social casino-style and sweepstakes-based games through its proprietary website www.bigpirate.com, its subdomains and its related features (“Website”) (together as the (“Services”)).

The company is dedicated to protecting your privacy rights and making our practices regarding your Personal Information more transparent and fair. This Privacy Notice (“Notice”) is designed to help you understand how we collect, store, use and share your Personal Information. This Notice applies whenever you visit our Website or otherwise access or use any of our Services.

Specifically, this Notice describes –

1. What types of data we collect?

2. Tracking Technologies

3. Why we collect your Personal Information?

4. With whom we disclose your data?

5. Marketing and Advertising

6. Your rights

7. International Transfer Of Personal Information

8. Retention of Personal Information

9. Security

10. Minors

11. Updates to this Notice

12. Contact Us

We strongly urge you to read this Notice and make sure that you fully understand and agree to it. If you do not agree to this Notice, please discontinue and avoid using our Services. You have the right to cease using our Services, pursuant to this Notice, at any time.

You are not legally required to provide us with any Personal Information, but without it we will not be able to provide you with the full range or with the best experience of using our Services.

This Notice is integrated into and forms part of the Terms and Conditions which is currently available at: [email protected].

What types of data we collect?

We collect Personal Information about you, meaning any information which potentially allows your identification with reasonable means (for example, email address or name, collectively "Personal Information"). This section sets out how and when we collect and process Personal Information about you. The information provided shall be used for the identification of the user and for account management by us.

1.1. Account Information. If you choose to register an account with our Services, we collect your full name, email address, password, phone number, birthdate and user nickname, as well as voluntary information, such as your profile picture. If you choose to log in, access or otherwise connect to the Services through a social networking service (such as Facebook, Twitter, Instagram, etc.), we may collect your user ID and/or username associated with that social networking service, as well as any information you make public using that social networking service or that the social networking service allows us to access. In addition, we may collect certain information as required under various regulations, as well as Know Your Client (“KYC”) and Anti-Money Laundering (“AML”) regulatory requirements, such as your source of funds.

1.2. Payment Information. When you decide to make payments in our Services, you will be required to provide us with your billing information. The information you will need to submit depends on which billing method you choose, including your bank account, ACH information, and other payment account information. For example, if you pay with a credit card, we will collect your card information. Additional terms and conditions of the payment providers may apply, which should be available in the transaction process.

1.3. Usage Information. When you use our Services, we collect technical information about your interaction with our Services. Such information may include gameplay recordings, geolocation data, IP address, unique identifiers (e.g. MAC address and UUID), as well as other information which relates to your activity in the Services.

1.4. Communication Information. When you send us an email or contact us via the support in our Website, we collect the Personal Information you provide us to communicate and provide you with necessary information for your gaming experience. This may include your name, email address and any other information you choose to provide.

1.5. Participant Behaviour and Game Play Information. We also process your information on sweepstakes entries, participation history, prize claim, session duration, and behavioural monitoring, session duration. We process participant behavior information for the prevention of money laundering and/or funding of terrorism, the prevention of fraud, ensuring safe gaming environment, improvement of quality of service and customer recommendations.

1.6. Sweepstakes and Prize Fulfilment Information. When you participate in our sweepstakes, we collect information necessary to administer your participation and, if applicable, to notify and deliver prizes. This may include your mailing address, contact details, proof of eligibility (such as proof of age or residence), and tax-related identification information where required by law. We may also process your information for publicity purposes (such as publishing your name and region of residence) where required under applicable law or according to the sweepstake rules.

1.7. Identification Documentation. We collect and store uploaded documents, in order to identify customers, to process your requests and/or to comply with effective laws and regulations. These documents are also used for the purpose of prevention and detection of fraud, prevention of money-laundering and terrorist funding.

Special Categories of Personal Information

Our processing of your Personal Information may also involve special categories of personal data, including but not limited to health data and self-exclusion information for the provisions and improvement of our Service.

We will only process such information, as well as disclose it to competent authorities (law enforcement bodies), where it is strictly necessary and required for the following purposes (to the extent permissible by applicable law): (i) prevention or detection of an unlawful act; (ii) prevention of dishonesty, malpractice or other seriously improper conduct, provided that obtaining your consent may prejudice those purposes.

Tracking Technologies

When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies ("Tracking Technologies"). These allow us to automatically collect information about you, your device, and your online behaviour, in order to enhance your navigation in our Services, improve our Services performance, perform analytics, customize your experience, and offer you, for example, tailored content and advertisements that better correspond with your interests.

Tracking Technologies may be placed by us or by third parties such as analytics providers, who run content on our Services.

We use the following categories of Tracking Technologies:

• Strictly Necessary Tracking Technologies – these Tracking Technologies are automatically placed when you access our Services and are essential to enable you to navigate around and use the features of our Services.
• Functionality Tracking Technologies – these Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services;
• Performance Tracking Technologies – these Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioural data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).
• Marketing Tracking Technologies – these Tracking Technologies are used to deliver tailored offers to you, based on your derived interests, as well as to perform email marketing campaigns. They are usually placed by our advertisers (for example advertising networks) and provide them insights about the people who see and interact with their ads, visit their websites or use their app.

You can manage your Tracking Technology preferences through your device or browser settings, also you may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). Please note that disabling some cookies may affect the functionality of the Services.

Why we collect your Personal Information?

This section explains for what purposes we use your Personal Information.

Providing users with a fair, balanced, and competitive experience on our Services is extremely important to us. Therefore, we strictly enforce prohibitions against cheating, hacking, account stealing, and any other unauthorized or fraudulent activity. When you create an account, play our games, or otherwise interact with our Services, we may use a variety of anti-cheat and fraud prevention technologies to help us identify and prevent malicious activity. These services may collect and analyse data about the game binary or your computer to detect cheating and may be provided by us or by third party service providers.

Where you have not consented (or have withdrawn your consent) to the processing of your Personal Information by us, we may continue to process your Personal Information: (a) where processing is required for the performance of the contract (i.e. the Terms of Use) between you and us; and/or (b) where processing is necessary for compliance with a legal obligation to which we are subject; (c) where processing is necessary for the purposes of a legitimate interest of the Company and its affiliates (including for marketing).

With whom we disclose your data?

We do not sell or share your Personal Information with third parties for cross-context behavioural advertising. However, note that we may disclose your Personal Information described below:

(a) Affiliated companies: We may disclose Personal Information internally within our affiliated companies and subsidiaries, for the purposes described in this Notice.

(b) Payment processors: We disclose your payment information with third party payment processors, for the purpose of facilitating your payments when using our Services. These third parties may have access to your Personal Information so that they may perform these tasks on our behalf.

(c) Service providers: Our service providers work on our behalf that may need access to certain Personal Information in order to provide their services to us. These companies include those we have hired to provide customer service support, operate the technical infrastructure that we need to provide the services and cloud storage vendors.

(d) Third Party Integrations: The Services allow you to integrate with certain third party services, such as in order to connect your Facebook or Apple account to our Services or to place purchases, in which case you will be bound by the terms and conditions and privacy notices of said third parties (e.g., Apple, Google or Facebook) – so please make sure that you read and accept them in advance. We do not receive or store your passwords for any of these third-party services.

(e) Compliance with laws and law enforcement entities: We may disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We may also be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.

(f) Auditors and advisers: We may disclose your data with our external auditors, advisors and professional service providers (e.g., lawyers, accountants, insurers) for ensuring our compliance with regulatory requirements and industry standards.

(g) Mergers and acquisitions: We will transfer, sell or otherwise share your data in case of entering into a business transaction such as merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets.

In addition to the purposes listed in this Notice, we share Personal Information with those Recipients for any of the following purposes:

• Storing such information on our behalf, for example by using cloud computing service providers;
• Processing such information to assist us with our business operations (e.g. to process payments and your deposits; authenticate your access; auditing our operations; detect and prevent fraudulent or illegal activity; etc.);
• Performing research, technical diagnostics or analytics;
• Communicating targeted advertising, as well as promotional and informational materials, in accordance with our marketing policy (see below, under "Marketing"); and
• Whenever we believe in good faith that disclosure is necessary to protect our rights or legal claims, enforce our policies, protect your safety or the safety of others, as well as to investigate or prevent any fraud, for security reasons or to help us with any other related technical issue.

Marketing and Advertising

We may use your Personal Information ourselves or by using our third-party subcontractors for the purpose of providing you with in-app promotional materials concerning the Services as well as products, services, websites and applications which relate to: (i) affiliated companies or (ii) Company's business partners and affiliates (collectively, “Marketing Affiliates”), which we believe may interest you.

These communications may be delivered through various channels, such as email, in-app notifications. We may also send you SMS upon obtaining your prior explicit consent.

You may at any time decline receiving further marketing offers from us or from our business partners and Marketing Affiliates by following the unsubscribe instructions provided in the message or by contacting us at [email protected] .

Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you in-app service-related updates and notifications.

Your rights

Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your Personal Information. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask to exercise the following rights.

6.1. Rights of access to your Personal Information:

You have the right to receive confirmation as to whether or not Personal Information concerning you is being processed and access your stored Personal Information, together with supplementary information.

6.2. Right of data portability:

You have the right to request us to move, copy and transfer your Personal Information easily from one IT environment to another, in a safe and secure way, without affecting its usability.

6.3. Right of rectification:

You have the right to request rectification of your Personal Information in our control in the event that you believe the Personal Information held by Company is inaccurate, incomplete or outdated (except in cases where the information is required to be kept in its original format under any applicable laws and regulations).

6.4. Right of deletion/erasure:

You have the right to request us to erase or delete Personal Information held about you at any time. You are, however, advised that with the deletion of your Personal Information, you might not be able to use the Service anymore or the account might be totally closed.

6.5. Right to limit use and disclosure of your sensitive Personal Information:

You have the right to request to limit the collection of your sensitive Personal Information, to that use which is necessary to perform our Services.

6.6. Right to lodge a complaint:

All requests, complaints or queries may be addressed to the Company to the following email address: [email protected] with the subject ‘Privacy’. We will consider any requests, complaints or queries and provide you with a reply in a timely manner. You also have the right to lodge a complaint with a supervisory authority. The list of supervisory authorities, and their contact details, can be found at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

6.7. Right to restriction of processing objection to processing and withdrawal of consent:

The participant may at any time request that the Company restricts or ceases to conduct certain data processes provided that there exists no other lawful basis on which the Company is authorized to process said data.

6.8. Right to opt-out of the sale or share of Personal Information:

In the event that we sell or share your Personal Information for behavioural advertising purposes, you have the right to submit a request to opt-out of the sale or share of your Personal Information. After you opt-out, we may continue disclosing some Personal Information to our partners to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services are working correctly and securely, providing aggregate statistics and analytics and preventing fraud.

Please note that these rights are not absolute and may be subject to our own legitimate interests, restrictions and regulatory requirements. You are welcome to contact us for any questions or requests through our contact details below. We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve this.

We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.

Authorized agent

(a) You can use an authorized agent to make a request to exercise your right under applicable laws on your behalf if:

i. The authorized agent is a natural person or a business entity; and

ii. You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right, please provide us with a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

(b) The request must:

i. Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized agent. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you; and

ii. Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.

(c) We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

(d) Making a verifiable consumer request does not require you to create an account with us.

International Transfer Of Personal Information

Since we operate globally, it may be necessary for the provision of our services and to the extent required for the specific purpose, as stipulated in this Notice to transfer your Personal Information to countries outside the European Economic Area ("EEA"). The data protection and other laws of these countries may not be as comprehensive as those in the EEA, in these circumstances we will take reasonable steps to ensure that your Personal Information is protected in accordance with our Notice through contractual means (such as by using the standard contractual clauses approved by the relevant European Commission for data transfer, as available here) or other means (such as ensuring that the European Commission decisions determined that such jurisdictions offer an adequate level of protection as available here).

For more information about the international transfer of your Personal Information, our contact details are available under the section below "CONTACT US?".

Retention of Personal Information

If you have registered with an account through our Services, we will retain your Personal Information during the period your account is active. In addition, we will retain your Personal Information for additional periods, to enable us to meet our legal obligations under applicable laws or regulations, such as the applicable KYC and AML regulations.

In addition, we may retain your Personal Information for longer periods, provided that retaining such information is necessary for our legitimate interests, such as fraud prevention and record keeping. We will keep any relevant Personal Information that we may need to defend ourselves against any claim(s), challenge(s) or other such action(s) by you and/or third parties for such time as it is necessary. Where your Personal Information is no longer required by us, we will either securely delete or anonymize the Personal Information in question.

If for any reason you wish to delete your Personal Information, please send us an e-mail to: [email protected] , and we will make reasonable efforts to address your request.

Security

We have implemented commercially reasonable administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Information. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. Such breaches can lead to things such as reputational harm, fraud or identity theft. Therefore, we encourage you to exercise discretion regarding the Personal Information you choose to disclose. If you feel that your privacy was treated not in accordance with our Notice, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly via our contact details available below.

Minors

We do not knowingly collect or solicit Personal Information from anyone under the age of consent (as determined under the applicable laws where the individual resides; “Age of Consent”). By accessing, using or interacting with our Services, you certify to us that you are not under the Age of Consent. In the event we learn that we have collected Personal Information from an individual under the Age of Consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Consent, then please contact us through the contact details available below.

Updates to this Notice

We reserve the right to change this Notice at any time. The most current version will always be posted on our Services (as reflected in the “Last Revised” heading). Your continued use of the Services after the Notice, or any subsequent update, is posted is deemed consent to the terms in the Notice.

Contact Us

RAFFLEFY LIMITED, with an address at 205 Christodoulou Chatzipavlou, Louloupis Court, 2nd Floor, Office 201 Limassol, Cyprus 3036 .

For any privacy or data protection queries, the company's Data Protection Officer can be reached via email at [email protected] with the Subject 'Privacy'.

If you have any further questions, please contact us by email at: [email protected].

We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time.