BOUNTYRING

1. INTRODUCTION

Skilltech Esports Ventures Ltd. ("Company," "we," "us," or "our") operates the BountyRing platform, including the website at bountyring.com and the BountyRing downloadable application or any other BountyRing services (collectively, the "Platform"). This Privacy Policy describes how we collect, use, disclose, store, and protect your personal information when you access or use the Platform.

By creating an account, accessing, or using the Platform, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, you must not access or use the Platform.

This Privacy Policy should be read in conjunction with our Terms and Conditions and Game Rules. Capitalized terms not defined herein have the meanings set forth in the Terms and Conditions.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

Account Registration Information

When you create a BountyRing account, we collect your email address, telephone number, username, and any other information you provide during the registration process. If you decided to register our Platform through a social networking service (e.g., Google, Facebook, Twitter, Instagram), we collect your userID, username associated with the social networking service, and any information you make public using that service.

Identity Verification Information

When you complete the identity verification (KYC) process through our Verification Partner (Veriff, Persona, or any other partner we may use), we collect your full legal name, date of birth, residential address, a copy of your government-issued photo identification document, social security number, photos data, audio data, selfie liveness data, or any other information which our Verification Partner may need. Our Verification Partner processes this information on our behalf and in accordance with its own privacy policy. We receive verification results and may retain certain identity information as required for regulatory compliance and fraud prevention.

Payment and Financial Information

When you make deposits or request withdrawals, we collect payment method details necessary to process the transaction, such as credit card numbers, bank account information, or digital wallet identifiers. Payment information is processed by our third-party payment processors. We do not store complete payment card numbers on our servers. We retain transaction records, including deposit amounts, withdrawal amounts, fees, transaction dates, and other related transaction information, for accounting, regulatory, and fraud prevention purposes.

Communications, Use and Support

When you contact us via website, desktop application, mobile application, email, in-app chat, in-game chat, any electronic messenger application, any interaction, surveys, or our support system, we collect the content of your communications and any attachments you provide. We may also retain records of your game track, in-game chat messages exchanged during Competitions for fair play enforcement purposes.

Referral Information

If you participate in our Refer a Friend Promotion, we collect information about your referral activity, including referral link usage and the registration status of referred individuals.

Public Areas

You may also provide information which will be displayed, posted, or published on the website or submitted to other users or third parties at your own risk. You should be aware that we have no control over the activities and actions of other users and/or third parties you choose to share your information with, and we do not guarantee that your information will not be accessed by unauthorized entities or persons.

2.2 Information Collected Automatically

Device and Technical Information

We collect information about the device you use to access the Platform, including device type, device model, operating system and version, unique device identifiers (such as advertising identifiers, IDFA, or Android Advertising ID), IP address, browser type and version, language settings, screen resolution, timestamp, battery level, available storage space, time zone, connection type, landline and mobile network information.

Geographic Location Data

We collect precise geographic location data through geofencing technology to verify that you are physically located in a jurisdiction where cash-enabled Competitions are permitted. Location data is collected each time you access a cash-enabled Competition and may be collected at other times during your use of the Platform for compliance purposes. You must enable location services on your device to participate in cash-enabled Competitions. We may also derive your approximate location from your IP address.

Gameplay Data

We collect detailed data about your gameplay activity, including Competition results, scores, kill/death ratios, match durations, in-game actions, movement patterns, input patterns, behavioral analytics, performance statistics, skill tier classifications, and other gameplay metrics. This data is used for matchmaking, skill-tier classification, anti-cheating analysis, behavioral monitoring, dispute resolution, and Platform improvement.

Usage and Log Data

We collect information about how you interact with the Platform, including pages or screens viewed, features accessed, session duration and frequency, clickstream data, referring and exit URLs, timestamps, queries, error logs, and crash reports.

Cookies and Similar Technologies

We may use cookies, web beacons, pixels, local storage, marketing, advertising and statistical identifiers, and similar tracking technologies to collect information about your interactions with the Platform. These technologies help us authenticate your session, remember your preferences, analyze usage patterns, and improve our services. You can manage your cookie preferences through your browser settings, but disabling certain cookies may impair your ability to use the Platform.

2.3 Information from Third Parties

We may receive information about you from third-party sources, including: (a) identity verification data from our Verification Partner; (b) payment transaction data and fraud signals from our payment processors; (c) analytics data from third-party analytics providers; (d) device and attribution data from mobile analytics services; (e) information from app stores (such as Apple App Store or Google Play) related to your download and use of the App; (f) marketing and advertising third-party websites and services; and (g) reports from other Users regarding your conduct on the Platform.

3. HOW WE USE YOUR INFORMATION

Platform Operations and Service Delivery

To create and manage your account; process entry fees, prize payments, deposits, and withdrawals; present content; facilitate Competitions; marketing; advertising; provide you information; verify your identity and eligibility; enforce geographic restrictions through geofencing; implement matchmaking and skill-tier classification; any other use you may consent to; and provide customer support.

Fair Play, Security, and Fraud Prevention

To detect, prevent, and address cheating, smurfing, collusion, match fixing, fraud, bot usage, unauthorized access, and other threats to Platform integrity; to conduct behavioral analysis and anti-cheat monitoring of gameplay; to implement KYC and CDD protocols; to comply with anti-money laundering requirements; and to enforce our Terms and Conditions and Fair Play policies.

Legal and Regulatory Compliance

To comply with applicable federal, state, and local laws, regulations, and legal processes, including skill-gaming regulatory compliance, tax reporting obligations (including IRS Form 1099-MISC reporting), consumer protection requirements, and geofencing mandates; to respond to lawful requests from governmental authorities; compliance with our Terms and Conditions; and to establish, exercise, or defend legal claims.

Communications

To send you service-related notices (such as account verification, payment confirmations, and security alerts), changes and updates about the Platform, and promotional materials (where permitted by law). You may opt out of promotional communications at any time.

Analytics, Research, and Improvement

To analyze usage patterns, monitor Platform performance, conduct internal research, develop and test new features and services, improve the user experience, and evaluate the effectiveness of our services and anti-cheat measures.

4. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information. We may share your information in the following circumstances:

Service Providers

We share information with third-party service providers who perform services on our behalf under contractual obligations to protect your information, such as:

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

Legal and Regulatory Disclosures

We may disclose your information: (a) to comply with a legal obligation, court order, subpoena, or other legal process; (b) to enforce our Terms and Conditions or other agreements; (c) to protect the rights, property, or safety of the Company, our Users, or others; (d) to regulatory and gaming authorities in connection with skill-gaming compliance; (e) as required for tax reporting; or (f) in response to lawful requests from governmental authorities, including law enforcement.

YOU WAIVE AND HOLD HARMLESS THE COMPANY AND ITS AFFILIATES FROM ANY CLAIMS RESULTING FROM ANY ACTION TAKEN DURING, OR AS A CONSEQUENCE OF, INVESTIGATIONS BY THE COMPANY OR LAW ENFORCEMENT AUTHORITIES.

Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or substantially all of our assets, your information may be transferred to the acquiring entity as part of the transaction. We will notify you of any such transaction and any choices you may have regarding your information.

Related Parties

We may share your information with our related parties, affiliates, subsidiaries, and parent company.

Auditors and Advisers

We may share your information with our external auditors, advisors, and professional service providers (e.g., testing labs, lawyers, accountants, etc.) to ensure we comply with industry standards, regulatory requirements, disputes, etc.

With Your Consent

We may share your information for other purposes with your express consent.

Aggregated or De-Identified Data

We may share aggregated or de-identified data that cannot reasonably be used to identify you for any purpose, including research, analytics, marketing, and industry reporting.

5. DATA RETENTION

We retain your personal information for as long as your account is active or as needed to provide you with services. After account closure, termination, or deletion (including deletion of inactive accounts), we will retain your information for a reasonable period necessary to fulfill our legal and regulatory obligations.

Specific retention periods: (a) account registration information: duration of the account plus five (5) years after closure; (b) identity verification records (KYC/AML): as required by applicable regulations, typically five (5) years minimum; (c) transaction and financial records: seven (7) years for tax and accounting purposes; (d) gameplay and behavioral data: duration of the account plus two (2) years after closure; (e) geolocation data from Competition sessions: one (1) year; (f) in-game chat and communication records: one (1) year; (g) support communications: three (3) years.

After the applicable retention period expires, we will securely delete or anonymize your personal information in accordance with our data destruction procedures. Aggregated or de-identified data may be retained indefinitely.

6. DATA SECURITY

We implement commercially reasonable technical, administrative, and organizational safeguards to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include: encryption of data in transit (TLS/SSL) and at rest; access controls and role-based permissions; regular security assessments and vulnerability testing; employee training on data handling; incident response procedures; and secure data destruction practices.

However, no method of electronic transmission or data storage is completely secure. While we strive to protect your information, we cannot guarantee its absolute security. You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account. If you believe your account has been compromised, contact us immediately at [email protected].

7. YOUR RIGHTS AND CHOICES

7.1 Access and Correction

You may access and update certain account information through the Platform settings. You may also contact us at [email protected] to request access to, correction of, or deletion of your personal information. We will respond to verified requests within the time periods required by applicable law.

7.2 Account Deletion

You may request deletion of your account and associated personal information by contacting [email protected]. Account deletion is subject to the withdrawal and fund forfeiture provisions of the Terms and Conditions. We may retain certain information as required by law or for legitimate business purposes, as described in Section 5.

7.3 Location Data

You may disable location services on your device; however, doing so will prevent you from participating in cash-enabled Competitions. Location verification is required for regulatory compliance and cannot be waived.

7.4 Marketing Communications

You may opt out of receiving promotional emails by following the unsubscribe instructions in the email or by contacting [email protected]. You may opt out of push notifications through your device settings. Even if you opt out of promotional communications, we will continue to send you service-related messages (such as account alerts, transaction confirmations, and security notices).

7.5 Cookies and Tracking

Most web browsers allow you to manage your cookie preferences. You can set your browser to refuse cookies or to alert you when a cookie is set. Disabling cookies may limit your ability to use certain features of the Platform. We do not currently respond to Do Not Track ("DNT") browser signals due to the lack of a uniform industry standard for DNT.

7.6 Data Portability

Where required by applicable law, you may request a copy of the personal information we hold about you in a structured, commonly used, and machine-readable format.

8. STATE-SPECIFIC PRIVACY RIGHTS

8.1 California Residents (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, "CCPA"): (a) the right to know what personal information we collect, use, disclose, and sell, including specific pieces of personal information we hold about you; (b) the right to delete your personal information, subject to certain exceptions; (c) the right to correct inaccurate personal information; (d) the right to opt out of the sale or sharing of your personal information for cross-context behavioral advertising (we do not sell personal information as defined by the CCPA); (e) the right to limit use of sensitive personal information; and (f) the right to non-discrimination for exercising your privacy rights.

To exercise these rights, contact us at [email protected] or submit a verifiable consumer request. We will verify your identity before processing your request. California residents may also designate an authorized agent to submit requests on their behalf with proper documentation.

Categories of Personal Information Collected

In the preceding twelve (12) months, we have collected the following categories of personal information as defined by the CCPA: identifiers (name, email, phone number, IP address); financial information (payment details, transaction records); geolocation data; internet or network activity (usage data, device information); biometric information (facial geometry data from liveness verification checks conducted by our Verification Partner); professional information (username, gameplay statistics); and inferences drawn from the above (skill tier, behavioral patterns).

Sensitive Personal Information

We collect the following categories of sensitive personal information: precise geolocation data (for geofencing compliance) and government-issued identification (for KYC verification). This information is used only for the operational purposes described in this Privacy Policy, not for inferring characteristics about you.

Disclosure for Business Purposes

We have disclosed personal information to the categories of service providers described in Section 4 for the business purposes described in Section 3. We have not sold personal information and do not share personal information for cross-context behavioral advertising as those terms are defined by the CCPA.

8.2 Colorado, Virginia, and Other States

Residents of states with comprehensive privacy laws (including Colorado, Virginia, Utah, Texas, Oregon, Montana, and other states that have enacted or may enact privacy legislation) may have similar rights, including the right to access, correct, delete, and port personal information, and the right to opt out of targeted advertising, profiling, and the sale of personal information. To exercise any applicable rights, contact us at [email protected]. If you are not satisfied with our response, you may have the right to appeal our decision by contacting us or by filing a complaint with your state attorney general.

8.3 European Economic Area, United Kingdom, and International Users

Skilltech Esports Ventures Ltd. is a company registered in the European Union. As such, to the extent that personal data of individuals located in the European Economic Area ("EEA") or the United Kingdom ("UK") is processed in connection with the Platform, the General Data Protection Regulation ("GDPR") and applicable UK data protection legislation may apply. In such circumstances, Skilltech Esports Ventures Ltd. acts as the data controller for such personal data.

While the Platform is designed for and targeted at users located in the United States, if we process the personal data of EU or UK data subjects, such processing is conducted in accordance with the GDPR and applicable UK data protection laws.

Lawful Bases for Processing

Where GDPR applies, we rely on the following lawful bases for processing personal data: (a) performance of a contract, where processing is necessary to provide the Platform and fulfill our obligations under the Terms and Conditions; (b) legitimate interests, where processing is necessary for fraud prevention, Platform security, analytics, and service improvement, provided such interests are not overridden by your rights and freedoms; (c) compliance with legal obligations, where processing is required by applicable law, including regulatory and tax obligations; and (d) consent, where you have provided explicit consent for specific processing activities, such as marketing communications.

Rights Under GDPR

If you are a data subject located in the EEA or the UK, you may have the following rights under applicable data protection law: (a) the right of access to your personal data; (b) the right to rectification of inaccurate or incomplete personal data; (c) the right to erasure ("right to be forgotten") of your personal data under certain circumstances; (d) the right to data portability, allowing you to receive your personal data in a structured, commonly used, and machine-readable format; (e) the right to restriction of processing under certain circumstances; and (f) the right to object to processing based on legitimate interests or for direct marketing purposes.

Right to Lodge a Complaint

If you believe that our processing of your personal data violates the GDPR or applicable UK data protection law, you have the right to lodge a complaint with a supervisory authority in the EEA member state of your habitual residence, place of work, or place of the alleged infringement, or with the UK Information Commissioner's Office (ICO), as applicable.

Cross-Border Data Transfer Safeguards

Where personal data is transferred from the EEA or the UK to countries outside the EEA or the UK (including the United States), we ensure that appropriate safeguards are in place to protect such data in accordance with GDPR requirements. These safeguards may include the use of Standard Contractual Clauses approved by the European Commission, adequacy decisions, or other lawful transfer mechanisms recognized under applicable data protection law.

9. CHILDREN'S PRIVACY

The Platform is not intended for use by anyone under the age of eighteen (18) (or nineteen (19) in Alabama and Nebraska). If you are under the applicable minimum age, do not register, use the Platform, or provide us any information about you. We do not knowingly collect personal information from children under the applicable minimum age. If we learn that we have collected personal information from a child, we will take prompt steps to delete such information and terminate the associated account. If you believe that a child has provided us with personal information, please contact us immediately at [email protected].

10. INTERNATIONAL DATA CONSIDERATIONS

The Platform is operated from and intended for Users located in the United States. If you access the Platform from outside the United States, you understand and agree that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction. By using the Platform, you consent to such transfer and processing. We do not intentionally offer the Platform to individuals in the European Economic Area, United Kingdom, or other jurisdictions outside the United States.

11. THIRD-PARTY LINKS AND SERVICES

The Platform may contain links to third-party websites, services, or applications that are not owned or controlled by the Company. This Privacy Policy does not apply to those third-party services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you access. Our inclusion of a link does not imply endorsement of the linked site or service.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will: (a) post the updated Privacy Policy on the Platform with a revised "Last Updated" date; and (b) where required by law or where changes are significant, provide additional notice (such as an email notification or an in-app alert). Your continued use of the Platform after the effective date of any changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Privacy Policy periodically.