Last Updated June 8th, 2023

OUR COMMITMENT TO PRIVACY

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY BEFORE SUBMITTING ANY PERSONAL INFORMATION.

ggCircuit ("we" or "us" or "our") operates https://ggcircuit.com and related software applications and any other features, tools, online and downloadable products, materials, or other services (including co-branded or affiliated services) offered from time to time by ggCircuit and EEG (together the "Service") is committed to protecting and respecting your privacy. Your privacy is important and to better protect your privacy we provide this statement to explain how we collect, use and share any personal data belonging to you and the choices you can make about the way your Personal Information is collected and used.

To make this policy easy to find, we make it available from every page on our Website. It is intended to help you understand:

• What information we collect from you
• How we use the information we collect
• How we share the information we collect
• How we store and safeguard the information we collect
• How to access and control the information we hold

APPLICATION OF THIS NOTICE

This Privacy Policy should be read in conjunction with our Terms of Use. By accessing and/or using the Website or our Services you acknowledge us collecting, processing, storing and sharing your Personal Information in the ways set out in this Privacy Policy. If you have any concerns about providing data to us or having it used in any manner permitted in this Privacy Policy you should not use the Website or our Services.

Your use of the Service and any information you provide through the Service remains subject to the terms of this Privacy Policy and our Terms of Use, as each may be updated from time to time.

Unless otherwise defined, terms used in this Privacy Policy shall have the same meaning as set out in the Terms and Conditions.

1. THE INFORMATION WE COLLECT

When you use our Services, we collect the following type of information:

Information you provide us with:

• Personal information provided when you register for an Account on our Website such as your name, date of birth, postal address, email address, phone number and any other details as may be requested from you either at the time of registration or thereafter as necessary for the continued use of our services and to meet our legal obligations where necessary.
• Information that you provide if you enter a competition or promotion on the Website or when you report a problem with the Website.
• Correspondence passing between you and us, including, but not limited to, any interactions with us on our customer service or social media channels.
• Responses to any surveys that we use for research purposes, although you do not have to participate in such surveys.

Additional Information Collected

• Details of the activities on the Service (such as game play data and stats, game sessions, coins, and rewards), transactions you carry out through the Website and of the processing of your Account including details of your payment history and amounts that you have staked on games and the amounts that you have won or lost.
• Details of your visits to the Website including, but not limited to, traffic data, location data, device data, weblogs and other communication data (including IP address and browser type).
• Pages on our Website visited, content viewed, links clicked all through the use of Cookies (please see our Cookie Policy for more information).
• Your social media profile details (name, profile photo and other information you make available to us) when you connect with or contact us through a social media account.
• Information gathered based on profiling activity (as further described below).
• Information from our partners and service providers, third party databases and other publicly available sources (such as social media) to comply with our legal and regulatory obligations in relation to confirming the age and identity of our users.

Mobile Applications

• Certain Mobile products and services ("Products") are currently supported by third party advertising partners that serve advertisements ("Third Party Advertisers"), including behavioral, location or interest-based advertising ("Interest Based Advertising") within our Services. These Third-Party Advertisers use technology to serve the advertisements and may link to them directly into our Products. They may automatically receive your device ID, IP address or geo-location data (limited to country/region) when this happens.
• When you use our mobile app, we also may collect mobile device information like operating system and hardware type, numbers or codes that are unique to your particular device (such as IDFA or an Android Ad ID), device information, default device language, the location of your device (at a GPS level), and app usage information. This data also may be linked to your other information, including your location data.
• Upon request we can provide you with our Third-Party Advertisers and Partners used within certain Products, and their respective privacy policies for information regarding their privacy practices.
• Your mobile device may provide you with the ability to limit this functionality.
• iOS (versions 10-13) - On your iOS device (iPhone or iPad), open "Settings > Privacy > Advertising" and turn on "Limit Ad Tracking" to opt-out of interest-based ads. Please see additional information from Apple here: https://support.apple.com/en-us/HT202074
• iOS (version 14.5+) - On your iOS device (iPhone or iPad) open "Settings > Privacy > Tracking" and turn off "Allow Apps to Request to Track"
• Android - Open the Settings app on your Android phone, tap Ads and enable "Opt out of interest-based ads".
• Please note that if you opt out of certain Interest Based Advertising, you may continue to receive contextual ads based on other non-personal information, such as ads related to the content of the Product you are using.

Children's information

• Protecting the privacy of young children is especially important to ggCircuit. For that reason, ggCircuit does not knowingly collect or maintain personal data or non-personally identifiable information from underage users other than as permitted by law in support of our internal operations.
• In this privacy policy any reference to underage users refers to those under the age of consent to the processing of personal data in their country of residence:
  • Croatia, Germany, Hungary, Ireland, Luxembourg, Malta, Netherlands, Poland, Romania, Slovakia - 16 or under
  • Czech Republic, France, Greece, Slovenia - 15 or under
  • Austria, Bulgaria, Cyprus, Italy, Lithuania, Spain - 14 or under
  • United States, United Kingdom and any EU countries not listed above - 13 or under

2. HOW WE USE YOUR INFORMATION

We will use the information we collect about you as described above for specific purposes, which shall include the following:

• Account Creation, Verification and Administration: We use personal information to create and verify your account with us. This is because we need to know that you are who you say you are and that you are at least 13 years of age. We also require this information to ensure the continued safe and secure administration of your account, to notify you of important changes to our service, provide customer or technical assistance, facilitate deposits and withdrawals and to ensure the continued compliance by you of our General Terms and Conditions.
• Customisation and Personalisation: We want to ensure that content from the Website is presented in the most effective manner for you and for your computer and we use information we collect to deliver you with information, products, offers or promotions that you request from us or which we feel may be relevant or interest you.
• Advertising and marketing activities: Subject to your account preferences, we use your personal information to notify you via various mediums (including by email, text, social media, push notifications, etc) of special offers and updated information regarding our various products and services and other products and services offered by carefully selected third parties if we feel they may be of interest to you. Any such notifications from us will always include instructions on how to opt-out of receiving future notifications. You can also easily opt in to or opt out of receiving further marketing from us or our carefully selected third parties at any time by sending us an email to privacy@ggcircuit.com. Please allow up to 48 hours for any changes you make to your marketing preferences to take effect. Please note, you may still receive important Service or Account updates from us even if you are opted out of receiving marketing communication. We may also use a combination of information collected from you (such as your email address, social media profile information, cookies, etc) to show you relevant, targeted and personalised advertisements across the internet and on social media.
• Legal and Regulatory Obligations: We are required to use and retain personal information to comply with our legal and regulatory obligations, such as the verification of your identity, the prevention , detection of investigation of a crime, the promotion of responsible gaming, sport integrity investigations, etc. We may also be required to use or disclose your personal information to respond to or comply with any requests from any competent court of jurisdiction, regulatory agency or such other enforcement or governmental authority or otherwise to protect our legitimate business interests.
• Statistical analysis and research: We are always looking for ways to make our Services smarter, faster, secure and more personalised to you and we use collected learnings, analytics and data from the information you provide us with to help us troubleshoot system problems, to improve and test the features and products on our Website, to measure the performance of our Services. If you choose to participate in a survey, any personal information you provide us with may be used for such research purposes.
• Profiling: We use information collected from you to carry out profiling of our customers based on a number of factors including your age, address, gaming activity, transactional data, interests and other similar such information in order to (i) personalise the Services, notifications and promotions we offer you, where you have given consent to; (ii) evaluate and mitigate risks to our business; (iii) to comply with our legal and regulatory obligations; and (iv) to show you and like-minded individuals relevant, targeted and personalised advertisements across the internet and on social media, where you have given consent to.
• Consent: We may use information collected by us where you have given us consent to use it for a particular purpose not specified above.

Third party content may from time to time appear on the Website or be accessible from the Website via links to other websites. If you follow a link to any of these websites, you leave the Website and enter sites that may or may not have their own privacy statements. We have not reviewed, do not monitor and are not responsible for the content on such websites or for the terms of their privacy statements. Please check these statements before you access or submit any personal data to these websites.

3. HOW WE SHARE THE INFORMATION WE COLLECT

We may disclose or transfer the information we collect from you to any of our associated companies or partners necessary for the provision of the Services to you. Please note, we are not in the business of selling information about you to advertisers or other third parties.

We may disclose your personal information:

• Where required to do so by law;
• if we believe in good faith that such action is necessary to:
  • comply with any legal process served on us;
  • protect and defend our rights of property; or
  • to protect the personal safety of Users of this Website, the Company or the public;
• to any regulatory body, licensing body or authority;
• to any platform or games supplier used in the operation of the Website or to otherwise provide the Services;
• to any other trusted and vetted third parties who provide services to or on our behalf through the course of the operation of the Website or the provision of the Services, including, but not limited to services such as information technology, payment processing, marketing, customer support, data analysis, identity and source of wealth verification and risk management.
• to any third party that purchases our company or our business. In the event of this, we will notify you in advance.
• If you participate in our Rewards Refer and Earn Programme (either as an existing customer making a referral or a new customer registering via a referral), we may share your participation and status within the Refer and Earn Programme with the person that you referred/referred you (as applicable).

Any third parties, agents or sub-contractors who are given access to your personal information will be required to keep the information confidential and not use it for any purpose other than to carry out the services they are performing for us.

4. HOW WE STORE AND SAFEGUARD THE INFORMATION WE COLLECT

Your personal data will be stored and processed on servers in the USA. From time to time your data may also be transferred to and processed on servers situated in other jurisdictions for the purposes set out above, including backup and disaster recovery. Such processing may be performed by us or on our behalf, by our staff, agents and sub-contractors who may be located anywhere in the world. Countries outside the USA may not always have strong data protection laws. However, where any storing, transfer or processing of your information is required outside of the USA, we will always take all appropriate steps to ensure that your information is used securely and in accordance with this Policy and applicable privacy regulations. Where we share with a third party located outside the USA, they are required to protect personal information we share with them. We also require that third-party service providers to whom a data transfer is made has appropriate safeguards in place to protect your personal information, in compliance with applicable data protection law and may not use any directly identifying personal information other than to provide services we contracted them for.

We shall retain and store your personal information for as long as we reasonably require it for legal or business purposes. In most circumstances, your information shall not be kept longer than 7 years provided there are no legal or regulatory requirements for us to retain your information for longer.

We will take all appropriate steps to ensure that your data is used and retained securely and in accordance with this privacy statement and will encrypt certain portions of your personal data where appropriate, including payment transactions if applicable. If we ever decommission or reallocate any computer equipment we will ensure that all sensitive information contained on such equipment will be permanently erased either using specialist software or by physically damaging the equipment.

Where you have chosen a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential and for preventing any unauthorised use of your Account.

We maintain appropriate technical and physical safeguards to protect your personal information against accidental or unlawful destruction or loss, alteration, unauthorised disclosure or access, use and all other unlawful forms of processing of the data in our possession. Unfortunately however, the transmission of information via the internet is not completely secure. While no organisation can guarantee complete security, we do take reasonable steps to implement appropriate physical, technical, and organizational measures to protect the personal information that we collect and process.

5. YOUR RIGHTS REGARDING THE INFORMATION WE HOLD ABOUT YOU

You have certain rights when it comes to the information we hold about you as detailed below. Some of these only apply in certain situations and may be subject to exemptions under data protection legislation. We will advise you in response to any request by you if any such limitations or exemptions apply.

• Access to Information: You can request a copy of the personal information that we have collected about you free of charge via the Website by contacting our Customer Services team at privacy@ggcircuit.com. For the added security of your personal information, when you request a copy of the information that we hold, you will be asked to provide us with proof of identification. Any such request will be dealt with within a reasonable time-frame and within the timeframes set by applicable data protection legislation from the date we have verified the identity of the person making the request.
• Correction of Information: You can also have factual inaccuracies in the personal information that we hold about you corrected by contacting our Customer Services team, who may require you to send in supporting documentation. Some personal information can be corrected from your account management page within the ggLeap client or via a ggLeap venue administrator.
• Right to Withdraw or Suspend Consent: Where we have relied upon your consent to process your personal data in accordance with this policy, you have the right to withdraw or suspend that consent. Any such withdrawal or suspension shall not affect any processing of your information that has taken place prior to your withdrawal. You can opt out of receiving marketing communications directly from any message received or by updating your preferences via your Account or by sending us an email to privacy@ggcircuit.com.
• Right of Deletion: You may request us to delete the information we hold about you. Please note, this right only applies in certain circumstances, and we may need to retain information to continue to comply with our legal and/or regulatory obligations.

ADDITIONAL PRIVACY POLICIES FOR CALIFORNIA RESIDENTS

The California Consumer Privacy Act (the "CCPA", as amended by the California Privacy Rights Act), provides California residents with certain rights regarding the processing of their personal data. Specifically, California Civil Code Section 1798.83 ("Shine the Light") permits our customers who are California residents to request, once per calendar year, the following information from us:

(i) a list of the kinds of personal information that we have disclosed to third parties for direct marketing purposes during the preceding calendar year; and

(ii) the names and addresses of all of the third parties that received personal information from us for direct marketing purposes during the preceding calendar year.

For inquiries regarding our disclosure policy, please contact us as described above. Requests must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code.

California Business and Professions Code Section 22581 ("California Privacy Rights for Minor Users") permits you, if you are a California resident under the age of 18, to view, correct or remove information provided by you or publicly posted by you. For inquiries regarding our disclosure policy, please contact us as described below in Section 10 "Your questions and how to contact us". Requests must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code. Any enquiries from underage users will be deleted upon completion.

Your Rights under the California Consumer Privacy Act (the "CCPA")

Our customers who are California residents have the following rights under the CCPA:

• The right to request the deletion of their personal information;
• With respect to the collection of personal information, the right to request, not more than twice in any twelve (12) month period, the following: (i) categories of personal information we have collected about that consumer; (ii) categories of sources from which the personal information is collected; (iii) business or commercial purpose for collecting or selling personal information; (iv) categories of third parties with whom we share personal information; and (v) specific pieces of personal information we have collected about you;
• With respect to the sale and/or disclosure of personal information, the right to request, not more than twice in any twelve (12) month period, the following: (i) categories of personal information that we have collected about the consumer; (ii) categories of personal information that we have sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold; and (iii) categories of personal information that we have disclosed about the consumer for a business purpose;
• The right to opt-out of the sale of personal information;
• The right to not be discriminated against for exercising any of the above described rights;
• Right to rectification of incorrect information;
• Right to limit the use of Sensitive Personal Information, by limiting the use and disclosure of your sensitive personal information surrounding race, precise geolocation, religion, union membership, genetics, biometrics, sexual orientation, and the contents of communications;
• Right to opt-out of Behavioral Profiling relating to profiling and serving ads based on behaviour;
• Automated Decision- Making, where you can ask us not to use automated decision-making to provide you with offers, products or services etc.
• Right to Data Portability. This right allows you to obtain some of your personal information in a format that enables you to transfer it across to another organisation where technically feasible.

Do Not Sell My Personal Information

To exercise any of your rights under the CCPA, please contact us as described above and be ready to provide your name, address, and email. We may ask for other information in order to confirm your identity. Any information we receive from you in order to confirm your identity will solely be used for such verification purposes.

You may also designate an authorized agent to make a request on your behalf. If you choose to designate an agent, please be sure the agent can

(i) provide written permission from you for the agent to make the request on your behalf, and

(ii) provide proof of his or her own identity.

Further Disclosures Under the CCPA

During the past twelve (12) months, we have collected the following categories of personal information from the following sources, for the following purposes, and have shared them with the following third party service providers:

Personal Identifiers & contact information: Information you give us when you sign up to access our services, or other information you choose to give us. Our purposes for collecting this information are:

• To create your profile and so you can access our services;
• To provide services you request;
• To identify you when you sign-in;
• To give you access to your user preferences;
• To contact you for your views on our services;
• To allow participation in special events or contests (if specifically approved by you);
• To notify you of changes or updates to our services; and
• For marketing purposes, based on your communication preferences.
• To create commercialized data products based on data collected from our services
• To monitor betting activity related to providing our services
• To improve our services, such as by improving and enhancing algorithms

Commercial Information: Information provided by you and/or third-party providers. Our purposes for collecting this information are:

• To verify your purchase of our services and process any refunds
• To reply to any queries and questions and to resolve complaints
• To carry out analysis and research to develop our services
• To create commercialized data products based on data collected from our services
• To monitor betting activity related to providing our services
• To improve our services, such as by improving and enhancing algorithms to protect you and the services by seeking to detect and prevent fraud or other acts in breach of our terms of service or policies relevant to the services

Technical and Device Information/Internet Activity: Information from your mobile or computer device when you use our services. Our purposes for collecting this information are:

• To provide you with an optimal experience
• To understand how you interact with our services
• To provide services you request
• To measure and analyze the use and effectiveness of our services
• To understand which of your devices are using our services
• To provide safe and fair wagering environments
• To track consents for use of personal information related to our services
• To serve advertisements within the services
• To customize and optimize the targeting of advertising both on our services and across third party websites, apps and services
• To operate and improve our services
• To fix errors
• To create commercialized data products based on data collected from our services
• To monitor betting activity related to providing our services
• To improve our services, such as by improving and enhancing algorithms

Feedback: Your questions, suggestions or views on the services. Our purposes for collecting this information are:

• To reply to your questions or queries
• To record comments and information which you provide on our gaming forums
• To conduct analysis and research to improve and develop the services

Third Party Information: Information about your use of our services that is shared with third party platforms and services connected with our services. Our purposes for collecting this information are:

• To enable us to provide tailored offers to you
• To facilitate sharing on social networks
• To facilitate your gameplay
• To create commercialized data products based on data collected from our services
• To monitor game activity and betting activity related to providing our services
• To improve our services, such as by improving and enhancing algorithms

The Categories of Parties With Whom We Share Personal Information

• to provide you with the services or support/information you have requested;
• for any other purpose related to the purposes for which your Personal Information was collected as described in this policy which you would reasonably expect, or which has been otherwise notified to you;
• when data is shared with casino partners and regulatory agencies for the purpose of verifying transactions and processing payments;
• the third parties or classes of third parties that ggCircuit has at the time of collection informed you of;
• to enable ggCircuit to participate in activities with business partners and sponsors,
• where the disclosure is required or authorized by law;
• where you have consented to its disclosure either expressly or by the circumstances and your conduct;
• ggCircuit will take all reasonable steps to ensure that any Personal Information which ggCircuit discloses to a third party is protected by that party.

Other than as stated in this Privacy Policy, we do not "sell" consumer data as most people would understand the term "sell". However, the CCPA defines the "sale" of information broadly to include activities we believe most people would understand as "information sharing". For example, the CCPA defines "sell," "selling," "sale," or "sold," as selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to another business or a third party for monetary or other valuable consideration. The term "other valuable consideration" is not defined in the CCPA. Notwithstanding that, we do not believe we "sell" consumer data as the term "sell" is defined under the CCPA. However, we do share consumer data with our affiliates, third party service providers, advertising partners, publishers and marketing partners as explained above in this Further Disclosures Under the CCPA section. To the extent those activities may constitute a "sale", we have shared such data with such parties the past twelve (12) months and anticipate continuing to share such data with the same parties in the next twelve (12) months. If our data sharing practices change, we will update this policy to reflect that change.

ADDITIONAL PRIVACY POLICIES FOR NEVADA RESIDENTS

Our customers who are Nevada residents have the right at any time to request that we do not sell the following information regarding them to third parties:

• the customer's first and last name;
• the customer's physical address which includes the name of a street and the name of a city or town;
• the customer's e-mail address;
• the customer's telephone number;
• the customer's social security number;
• the customer's identifier that allows a specific person to be contacted; or
• any other information concerning a customer collected from the customer through our Internet website or online service and maintained in combination with an identifier in a form that makes the information personally identifiable. To exercise your right to opt out of the sale of Covered Information under Nevada law, please contact us and be ready to provide your name, address, and email. We may ask for other information in order to confirm your identity. Any information we receive from you in order to confirm your identity will solely be used for such verification purposes.

CHANGES TO OUR PRIVACY POLICY

We may amend or vary this statement at any time and with immediate effect by updating this web page and you can see when this Statement was last updated by checking the "last updated" date displayed at the top of this Statement. Continued use of the Website following any such posting shall constitute acceptance of the revisions or changes.

THE TERMS OF THIS PRIVACY STATEMENT ARE TO BE GOVERNED BY AND CONSTRUED IN ACCORDANCE WITH THE LAWS OF THE UNITED STATES OF AMERICA, INCLUDING BUT NOT LIMITED TO THE FEDERAL TRADE COMMISSION ACT AND ANY DISPUTES THAT CANNOT BE RESOLVED SHALL BE SUBJECT TO THE EXCLUSIVE JURISDICTION OF THE STATE OF NEW YORK.

HOW TO CONTACT US

If you would like to contact us for any reason regarding our privacy practices or to request a copy of the personally-identifiable information that we have collected about you via the Website please write to our Customer Services team at privacy@ggcircuit.com. https://www.ggcircuit.com (the "Website")

COOKIES POLICY

We use cookies to deliver you a better and more personalised Service when using our Website. This policy explains what cookies are, how we use them and how to manage their use.

1. What is a Cookie?

Cookies are small text files that contain information that are downloaded to your computer, tablet, smartphone or any other such device that you use to access our Website. Each time you return to our Website, the cookies are sent back to us so we can recognise who you are and what device you are using.

You can find more information about cookies at http://allaboutcookies.org.

2. How We Use Cookies

Cookies enable us:

• To estimate our audience size and usage pattern.
• To store your passwords and information about your preferences so as to allow us to customise the Website according to your individual interests.
• To speed up your searches.
• To recognise you when you return to the Website.

The Cookies we use general fall into four main categories as follows:

• Essential Cookies: These cookies are essential to enable you to navigate our Website, use our Services and to allow you to return to pages previously visited.
• Functionality Cookies: These cookies allow us to recognise you when you return to our Website and remember any of your user preferences (e.g. preferred language). Our ability to recognise you helps us improve your user experience.
• Fraud Prevention Cookies: These cookies store information that helps us prevent any fraudulent or unlawful use of our Website.
• Tracking Cookies: These cookies allow us to identify where a user has come from before they accessed our Website.
• Performance and Analysis Cookies: These cookies are used to collect information on our Website's usage and to enable us to deliver you relevant information and measure the effectiveness of the content you are seeing.

Third party content may from time to time appear on the Website or be accessible from the Website via links to other websites. If you follow a link to any of these websites, they may have their own cookie policy. We have not reviewed, do not monitor and are not responsible for the use of cookies on such websites or for the terms of their privacy statements. Please check these statements before you access or submit any personal data to these websites.

3. How to Manage Cookies

You may block the use of some or all cookies by activating the setting on your relevant web, tablet or phone browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will automatically issue cookies when you log on to the Website.

For more general information on cookies and their use, please visit http://allaboutcookies.org

For more information about online behavioural advertising cookies and opt-out controls, please go to http://www.youronlinechoices.eu/.

More information regarding opting out of platform-based advertising can be found at https://www.appnexus.com/cookie-policy.

If you would like to contact us for any reason regarding our cookie policy, please write to our Customer Services team at privacy@ggcircuit.com.

Your information choices

You can choose not to receive tailored online advertising on this site and other sites and learn more about opting out of having your information used for tailored advertising purposes by accessing one of the following resources:

• For EEA, Switzerland, and UK: http://www.youronlinechoices.eu/
• For Canada: http://youradchoices.ca/choices/
• For U.S. and rest of world:
  • http://www.aboutads.info/choices/
  • http://optout.networkadvertising.org/

Note that if you choose not to receive tailored ads, you will still see online advertisements, but they will be general and less relevant to you.