Privacy Policy

Last Updated: June 21, 2025

INTRODUCTION

Playersbest Inc. (herein also referred to as "Company" or "we" or "us" or "our") respects your privacy and is committed to protecting it by complying with this policy and applicable laws. The information we collect is used to provide you with the best online experience while mitigating any possible security risk. We take your privacy seriously and hope the following information gives you complete transparency regarding your rights, the information we gather and how we use it.

All collection, use, retention, and disclosure of personal information is in compliance with applicable laws including the applicable U.S. laws, including the California Consumer Privacy Act ("CCPA").

This policy describes:

• The types of information we may collect from you or that you may provide when you use our Lucky Prize mobile application (the "App") as well as any other related products and services offered through the mobile applications we own and that link to this policy (collectively, the "Service(s)").
• How we collect, use, disclose, and protect the personal information of individuals who use the Services or access the App ("you" or "your" or "user").
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We do our best to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited legitimate purposes.

Privacy laws generally define "personal information" as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information generally does not include business contact information, including your name, title, or business contact information.

This policy applies to information we collect, use, or disclose about you:

• When you use or access our App or use our Services.
• In email, text, and other electronic messages between you and us in connection with the use of our Services.
• When you use any other mobile apps, official social media platforms, or other online properties through which the Company offers the Services and that are linked to this Privacy Policy.

The App may include links to third-party iGaming websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party Website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and are not responsible for their data-collection practices, even if they are linked from our App. We encourage you to read the privacy policy of every third-party website and/or mobile application you visit.

This policy DOES NOT apply to information that:

• We collect offline or through any other means, including on any other company or third-party website.
• You provide to or is collected by any third party, through any application or content that may link to or be accessible from or on the App.
• Is collected through online websites or services that we do not own or control, including websites or services of other users of our Services.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, you must decline to use our Services. By accessing or using our Services, you indicate that you understand, accept, and consent to the practices described in this policy. Where required by law, we will obtain your explicit consent before collecting, using, or disclosing your personal information. This policy may change from time to time (see Changes to our Privacy Policy). We will notify you of any changes, and your continued use of our Services and/or access to our App following such notification will be deemed as your acceptance of those changes. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your personal information.

INFORMATION WE COLLECT ABOUT YOU AND PARTICIPANTS

We collect and use several types of information from and about you, including:

• Personal information, that we can reasonably use to identify you directly or indirectly, such as your full name, e-mail address, age, date of birth, phone number, Internet protocol (IP) address used to connect your computer or cell phone or digital tablet ("Device") to the Internet, username, password or other similar identifier and any other identifier we may use to contact you ("personal information").
• Transaction and experience information: When you use our Services or access our App for example, to make payments towards purchases we collect information about the transaction, as well as other information associated with the transaction, such as amount paid for products or services.
• Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as age, demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Service feature. When appropriate, we may anonymize or pseudonymize personal data to protect user privacy while still allowing for data analysis and service improvement.
• Technical information, including your login information, browser type and version, Device ID, Device type, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our App, and usage details.
• Non-personal details about your App interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our App (including date and time), page response times, download errors, username on a social network, referring webpages or sources through which you accessed our App.

HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect your information, including through:

• Direct interactions with you when you provide it to us, for example, by filling in information on the App to create your account or corresponding with us by phone, email, or otherwise.

The information we collect directly from you as you use our Services or access our App may include:

• Information that you provide by filling in forms on our App. This includes personal information provided at the time of signing up or creating an account to use Services. We may also ask you for information when you report a problem with our Services.
• Records and copies of your correspondence (including email addresses and phone numbers) if you contact us.
• Your responses to surveys/polls that we might ask you to complete/participate in for research purposes and promotional purposes.
• Details of transaction information you carry out through our App.

• Automated technologies or interactions. As you navigate through and interact with our App, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, Browse actions, and patterns, including:
  • Details of your visits to our App, including traffic data, location data, logs, and other communication data and the resources that you access and use on the App.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical information and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our App and to deliver a better service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Recognize you when you return to our App.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our App. In line with the California Online Privacy Protection Act (CalOPPA), we will not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
• Necessary / Essential Cookies. These cookies are crucial for providing you with services accessible through the App and facilitating the use of certain features. They aid in user authentication and safeguard against fraudulent utilization of user accounts. In absence of these cookies, the requested Services cannot be rendered, and we solely utilize them to deliver our Services to you.
• Web Beacons. Pages of our App and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related App statistics (for example, recording the popularity of certain App content and verifying system and server integrity).
• Telemetry. We may utilize telemetry to gather and send specific technical data and usage information. Telemetry enables us to oversee and analyze the performance of our services, improve user experience, and address any issues. This could encompass details like device type, operating system, browser type, IP address, page load times, errors, and other interactions with our platform.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Services including the App and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
• To respond to correspondence from you, contact you when necessary or request feedback, and send you information about the Company or its Services.
• To provide you support or assistance with regard to our Services.
• To process orders and transactions that you request and generate related invoices.
• To send emails and other communications according to user preferences or that display content that we think will interest users.
• To improve the Services, including testing, research, internal analytics and product development.
• To conduct fraud protection, security and debugging related activities.
• To create and manage your user accounts or profile.
• To provide you with notices about your account, including expiration and renewal notices.
• To personalize the Services, App content and communications based on your preferences.
• To notify you about changes to our App or Services we offer or provide though them.
• To improve our Services, marketing, or customer relationships and experiences.
• To market our Services and services of third parties that you may be interested in.
• To conduct activities related to fraud protection, security and debugging.
• To carry out our obligations and enforce our rights arising from any contracts with you or to comply with legal requirements.
• To fulfill the Company's legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities.
• To carry out other business purposes stated when collecting users' personal information or as otherwise set forth in applicable data privacy laws.
• To protect the rights, property or safety of users, the Company, or another party.
• To resolve disputes, if any.

The following categories of persons within the Company will have access to your personal information:

• Customer Service
• Billing
• Persons supporting privacy officer
• Fraud Prevention and Security
• Lawyers and compliance

Please note the said personnel will only have access necessary to complete their duties or carry out mandates of contracts.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated/anonymized/de-identified information about our users, and information that does not identify any individual, without restriction subject to applicable laws.

We may disclose personal information that we collect, or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our customers and users is among the assets transferred.
• To different third parties we use to support our business such as security and fraud prevention consultants, analytics providers that help us improve our services, and product fulfillment and delivery providers. Please note that these third parties are contractually obligated to keep the personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
• To third parties if users access their services from the App.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• To enforce or apply our Terms & Conditions of Use and other agreements.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or other third parties.

We may also disclose your personal information without your consent:

• To comply with any subpoena or order of the court.
• To a public body or law enforcement agency to assist in an investigation of an offense under the laws of the United States of America, including laws of a specific state, as applicable.
• To comply with a request of a regulatory body.
• To comply with any and all applicable laws.

TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy. Where permitted by the privacy laws of the jurisdictions, we may share personal information with third parties for various purposes, including but not limited to:

• API Integrations
• SDKs (Software Development Kits)
• Pixel Tracking
• Data Aggregators
• Consent Mechanisms

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as U.S. laws. The Company takes precautions to ensure the safety and integrity of personal information that is transferred to another country. These precautions are subject to the legal requirements of the countries to which we transfer personal information, including lawful requirements to disclose information to law enforcement and government agencies in those countries. Whenever we engage a service provider, we require that their privacy and security standards adhere to this policy, U.S. privacy laws, and other applicable laws.

You are welcome to contact us to obtain further information about Company policies regarding service providers outside of the United States. See Contact Information and Challenging Compliance.

By submitting your personal information or engaging with the App, you consent to this transfer, storage, or processing.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this App may not be accessible or may not function properly. For more information about tracking technologies, see How We Collect Information About You.
• Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your email address/contact information used by the Company to promote our Services, you can opt out by sending us an email stating your request to apps@playersbest.com. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to the Company as part of a service experience.

DATA SECURITY

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The security measures include:

• Encryption
• Access Controls
• Authentication Mechanisms
• Regular Software Updates and Patch Management
• Firewalls and Intrusion Detection/Prevention Systems (IDS/IPS)
• Secure Coding Practices
• Security Vulnerability Assessments
• Penetration testing
• Security Monitoring and alert mechanisms
• Employee Training and Awareness
• Privacy policies and user consent
• Compliance with regulatory standards, including applicable US regulations

The safety and security of your information also depends on you. Where you have chosen a password for access to our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

While we strive to use commercially acceptable means to protect your personal information, unfortunately, no transmission of information via the Internet is 100% secure. As such we cannot guarantee the security of your personal information transmitted to our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the App. We strongly encourage users to keep their login credentials confidential and secure.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Under circumstances, we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose, such as statistical and market analysis, product development, and marketing, without further notice to you or your consent.

You have the right to correct or delete the personal information we have collected about you. You can request access to, correction of, or deletion of your personal information by contacting us using the information provided in the CONTACT INFORMATION AND CHALLENGING COMPLIANCE section below. We will respond to your request within 30 days. To request deletion of your personal data, please submit a verifiable request specifying the information you want deleted. Upon receiving and verifying your request, we will delete your personal information from our active systems and notify any third-party processors to do the same, unless retention is required by law or for legitimate business purposes.

PEOPLE UNDER THE AGE OF 18

Our Service is not intended for people under the legal age of majority in their respective jurisdiction. No one under the legal age may provide any personal information to or on the App. We do not knowingly collect personal information from people under the legal age. If you are under the legal age, do not use or provide any information on the App or on or through any of its features, register to use any Services, use any of the interactive or public comment features of our Service, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use.

If we learn we have collected or received personal information from a person under the legal age, we will delete that information. If you believe we might have any information from or about a person under the legal age, please contact us at apps@playersbest.com.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and up-to date. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.

You can review and change your personal information by logging into the App and visiting your account profile page. You can also request us to correct any errors or omissions with respect to your personal information. If we are satisfied such request is reasonable, we will correct the relevant information and provide an update about the correction to any third parties with whom your personal information was shared within a year before the date the correction was made.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you must send us an email at apps@playersbest.com to request access to, correct, or delete any personal information that you have provided to us.

We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Accessing your personal information is free. However we may charge you a fee to access your personal information, should the request be deemed to be excessive or repetitive. We will notify you of any fee in advance.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. We will provide access to the personal information free of charge. However, should the number of requests exceed one per calendar year, we may request you to pay a minimal fee to provide access to the personal information. You will be provided the access to personal information within thirty (30) business days after it is requested, unless we are provided an extension by the relevant authority or under applicable law.

Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at privacy@playersbest.com.

WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at apps@playersbest.com. Please note that if you withdraw your consent, we may not be able to provide you with any/all Services. We will explain the impact to you at the time to help you with your decision.

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page. If we make any changes to how we treat our users' personal information, we will notify you through an email/notice on the App home screen. In case you do not agree to the changes you have the option to decline the changes and discontinue the use of our Services. Should you have any requests with regard to such changes you can write to us at apps@playersbest.com.

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our App and this privacy policy to check for any changes.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. If you want to use any of your rights mentioned in this policy, you can do that by getting in touch with us. However, please understand that these rights are not absolute. This means we might not be able to fulfill your request completely or might have to decline it. We will provide you with reasons if we decline your requests.

Please contact us at: apps@playersbest.com

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.

While we ask that you reach out to us in the first instance to allow us the opportunity to address your concerns, note you have the right to contact your own data protection supervisory authority.

In case we are unable to address your complaints about how your personal information is handled you can make a complaint to your relevant local data protection supervisory authority.