Privacy Notice dated 11/3/2022

Introduction

This Privacy Notice (the “Notice“) sets out how AbZorba Games registered in Austria with number ATU 69356029 and address at Wiedner Hauptstrasse 94, 1050, Vienna (the “Company” “we” “us” or “our“) collects and process through the mobile applications Live Blackjack 21, Live Poker, Live Baccarat and Live Roulette (“Apps“) the Player´s personal data. Personal data means any information from which the player (“you“, “your” or “Player“) can be directly or indirectly identified such as a name, location, online identifier, gender, financial data, etc., (“Personal Data“). This Notice provides also the Players´ rights related to their Personal Data.

You should read this Notice carefully before using the Apps. If you use or register via the Apps, or submit a query to us via the Apps or other means, including telephone or mail, you accept this Notice. If you do not accept this Notice, please not use the Apps.

This Notice is integral part and applies together with the Apps General Terms and Conditions (the “Terms“), available here https://abzorbagames.com/terms-of-service/. The terms not defined in this Notice shall have the same meanings as defined in the Terms. Therefore you will need to read and understand the Terms in addition to this Notice.

We are highly committed to preserve your privacy and deliver secure and legally compliant services. This Notice has the following sections:

• Who controls the data?
• How can I send queries on personal data protection?
• What kind of Personal Data does the Company process?
• For what purposes are the Personal Data processed?
• On what legal basis are the Personal Data processed?
• What is the data retention period?
• Security and privacy measures
• Who can have access to the Personal Data?
• Is Personal Data transferred abroad?
• What are the Players’ rights on Personal Data?
• Notice modifications

Who controls the data?

The Company controls the processing of your Personal Data. This activity is supervised by the Austrian Data Protection Authority.

How can I send queries on personal data protection?

Please read first this Notice. In all cases you can send the queries related to this Notice in the following e-mail address [email protected] Our teams and Data Protection Officer (DPO) shall address them with the due attention.

What kind of Personal Data does the Company process?

Depending on you activities and services chosen on the Apps, we processes all or part of the following data:

Data provided by you during the creation of the account. They may include, but are not limited to: name, surname, email address, date of birth, gender and ID number; Apps activity data, that may include but are not limited to: device data, source and destination data, nickname, player ID, account username and password, gaming transactions, data provided to customer services (including emails and phone calls);

Data that may be provided by government authorities and/or duly authorized/licensed third party companies in order for us to deliver the Terms services, fulfill regulatory obligations and exercise our legal rights;

Data provided by third parties who’ve obtained in advance your permission to share their data in order to offer certain services e.g. social media or various mobile applications (where applicable);

We may allow the Apps user to create a “guest account”, also known as “try-mode”. These accounts involve a very limited amount of data such as device number and tokens. In all cases these data are anonymized. The users may decide to convert the “guest account” into a Player account by completing the registration process as provided in the Terms.

For what purposes are the Personal Data processed?

We process your data for the following purposes:

1. administer the Apps, including setting up and operating your account;
2. ensure the accuracy of your data for the purpose of age verification, preventing fraud, cheating, reducing business risks and protecting the integrity of the games. These activities may include a degree of semi-automatic profiling, based on your registration and gaming activity data;
3. fulfil the provisions contained in Apps Terms;
4. process online payments with third party payment providers and/or financial institutions;
5. provide you with customer support, including (where applicable) telephone;
6. comply with applicable laws, regulatory obligations or respond to requests from government authorities. These obligations are mainly set in financial laws, anti-fraud and responsible gaming. These activities may include a degree of semi-automatic profiling, based on your registration and gaming activity data;
7. protect our rights and our related parties. In some cases we may believe that it is necessary, including in good faith, to record and disclose data to: (i) protect, enforce, or defend our legal rights, privacy, safety or property, (ii) protect your and public safety, privacy and security , (iii) or for business risk management purposes;
8. improve the security, services and features provided by the Apps. This may include, partially customized services and tools, conduct research and surveys, obtain your feedback, internal trainings and Affiliates services;
9. complete potential merger or sale of assets. If we sell all or part of our business or assets, or are involved in a merger or transfer we may disclose and transfer your data to the other party(s);
10. further to your specific and optional consent, offer customized marketing communications fitting your interests and expectations. These are based on registration and gaming activity data; and
11. further to your specific and optional consent, offer direct marketing communications that are of (i) generic or partially based on your gaming journey and/or customized (ii) via: email, instant messages, and (where applicable) chats, SMS and telephone.

We shall inform you in case the data may be processed for other purposes and parties.

On what legal basis are the Personal Data processed?

The processing of Personal Data for the purposes of:

• The above sections from (1) to (5) are necessary for the execution of the Apps Terms. Therefore are mandatory as otherwise the services could not be provided;
• The above section (6) is required by law and it is also mandatory;
• The above section (7) to (9) are based on our legitimate interest and include business risk management and protecting of gaming products integrity. These activities are adequately balanced with your interest since the data processing is performed within the limits strictly necessary for these activities. You can object the processing at any time as provided in this Notice;
• The above sections (10) and (11) are optional. Without your consent we shall not provide generic and/or customized marketing communications.

What is the data retention period?

These periods and criteria will apply, unless a different period is required or permitted by law or we have reasonable belief that it is necessary:

data collected for the purposes of the above sections from (1) to (9) is retained during the execution of the Apps Terms. Plus the retention periods set or allowed by specific laws, after the termination of the services;

data collected for the purpose of the above sections (10) and (11) is retained during the execution of the Apps Terms and/or until you have required their deletion.

In case of further queries you may contact us at the email address indicated in this Notice.

Security and privacy measures

We process the data with partially or fully automated electronic means and protected them with adequate security measures. The activities that may produce significant legal effects such as decisions based on profiling, involve always a human intervention and/or final decision. We use appropriate legal, administrative, technical, personnel and physical measures to safeguard personal data against loss, theft and unauthorized use, disclosure or modification.

The Apps may contain links to and from partner networks and/or third party websites/apps. If you follow a link to any of these websites/apps, should note that they have their own privacy policies and general terms and conditions. We do not accept any responsibility or liability for their content. Please check such policies and terms before accepting and submitting any information to them.

Who can have access to the Personal Data?

The data can be processed by recipients located within or outside of the European Economic Area (EEA) in compliance within these limits:

• our employees who are responsible for the processing and safekeeping of the data;
• our parent company, some sister companies and third party service providers to offer the Terms services, e.g. marketing services or our legitimate interest. This may include employees, associates, agents, sub-contractors and product providers; and
• government authorities to comply with the legal obligations. This may involve the reporting of fraudulent or criminal suspicion and responsible gaming, to relevant authorities other authorized third parties.

Third party access to your data is limited only to the information necessary to perform their function on our behalf or as required by law. They shall be made subject to confidentiality and data protection obligations provided by law and as considered necessary by us.

You can contact us in case you need further information on the data processors.

Is Personal Data transferred abroad?

We shall not transfer your data outside the EEA unless the due safeguards are in place.

Some non-EEA countries are recognized by the European Commission (EC) as providing an adequate level of data protection. The list is available at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

In case of transfers to countries not considered adequate by the EC, we will put in place appropriate safeguards to protect the data and in compliance with the data protection laws, such as standard contractual clauses adopted by the EC as per the EU General Data Protection Regulation 2016/679 (the “Privacy Regulation”).

You can contact us in case you need further information.

What are the Players’ rights on Personal Data?

You can at any time:

• obtain confirmation of the existence of personal data. This information is primarily provided in your account;
• know the origin, purposes and method of data processing and the logic applied to electronic processing . This information is provided in this Notice and when you use the App features.
• request to update, correct or integrate further relevant data. This is provided via the customer service;
• revoke at any time, the data processing consent. It does not affect the lawfulness of the data processing based on a previous given consent. This is offered via specific tools e.g. opt-out or un-subscriptions;
  • request to restrict the processing where:
  • you contests the accuracy of the data until we have taken sufficient steps to correct or verify the accuracy;
  • the processing is unlawful but you do not want that we erase the data;
  • we no longer need the data for the provided purposes, but you require them to establish, exercise or defend a legal claim; or
  • you have objected the data processing justified by legitimate interests, pending verification if we have legitimate grounds to continue processing;
• object the data processing, including those based on our legitimate interest and (where applicable) the decisions being taken by fully automated means. This request may result in the termination of the services provided to you;
• request the erasure of data without undue delay. This request may result in the termination of the services provided to you;
• receive an electronic copy of the provided data, if you like to port them to a different service provider. This service is provided by the customer service; and
• lodge a complaint with the data protection authority.

Unless otherwise provided, these services are offered by sending a written request. They are free of charge however in certain circumstances we may apply a reasonable fee and fully or partially refuse the request. We will do our best to accommodate your requests but sometimes other legal obligations or third party rights may take precedence.

Your requests shall be handled within one month of receipt. This may be extended by two further months, based on complexity and number of the requests.

Notice modifications

This Notice is valid from the date indicated in its header. We could make further modifications due to business developments or legal and regulatory changes. You shall be notified in advance in case of significant changes.