PERSONAL DATA PROTECTION POLICY

PREAMBLE

Here at WINAMAX, we understand the importance of your personal data and your private life.

In this regard, this personal data protection policy details the conditions under which WINAMAX, a public limited company registered in the Paris Trade and Companies Register under number 492 155 932 (hereinafter "We" or "WINAMAX"), proceeds, as controller, to the processing of your personal data.

In order to build a relationship of trust with its customers, WINAMAX is committed to processing your personal data in accordance with the regulations applicable to the protection of personal data, and in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27^th April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter "GPDR"), and Law No. 78-17 of 6^th January 1978 relating to data processing, files and freedoms (hereinafter together the "Regulations").

As such, we implement the main principles of the Personal Data Regulation in the following manner:

• Lawfulness: your personal data is collected for specific, explicit and legitimate purposes and on an adequate legal basis;
• Transparency and fairness: you are informed of the processing that we carry out and of their modalities by means of the present data protection policy or by any other document provided for this purpose, no processing of your personal data is carried out without your knowledge;
• Minimization: we only collect personal data that is strictly necessary for the purpose for which it is being processed;
• Limitation of storage time: we keep your personal data for the time necessary to carry out the processing for which they were collected or, if this is the case, for the period set by law;
• Data security: we have put in place appropriate technical and organizational measures with respect to the personal data collected, in order to ensure the integrity and confidentiality of such data and to protect it against malicious intrusion, loss, alteration or disclosure to unauthorized third parties;
• Commitments of our service providers and partners: we choose our subcontractors, service providers and partners carefully and require them to ensure a level of protection of your personal data equivalent to ours, to use your personal data only to the extent necessary to provide the services we have entrusted to them, and to comply with the Regulations.

In application of the GDPR, the term "personal data" refers in the context of this policy to any information about you that can directly or indirectly identify you as a physical person.

This policy applies to all of our websites, applications, online sports betting and poker offers including occasional physical and online events and tournaments (hereinafter "our Offers"). We may make changes to these terms and conditions as a result of changes in applicable law or changes in our business. We will, of course, inform you of any changes to this policy and we also invite you to consult this page regularly.

WHAT DATA DO WE COLLECT?

We collect the personal data of any user of our Offers. The term "user" includes any user of and/or player registered on our website (hereinafter the "Site") and our application (hereinafter the "Application"), and/or any participant in a WINAMAX tournament or championship.

Personal data collected directly from you:

The personal data that we collect are those that you communicate directly to us, notably when you register and create your online account, when you fill out a contact form, play online or participate in one of the events and occasional tournaments that we organize.

This data includes identification data (name, first name, date of birth, postal address, email address, telephone number), banking data (bank details, credit card), connection data, location and traffic data, data relating to any complaints you may have, gaming data (frequency and volume of bets, history of bets, winnings and losses), etc.

Indirectly collected data:

We obtain some personal data indirectly. This is notably the case of data communicated by third parties such as organizations of prevention of fraud or excessive play, and commercial partners of WINAMAX.

Cookies :

We use cookies and other tracking devices to collect personal data about you for some of the purposes described below. This data can be for example your connection data, navigation data, IP address, preferences and interests, etc. You can find information about cookies in the dedicated section of this policy and the "Cookies - Cookie management" section.

HOW DO WE USE YOUR PERSONAL DATA?

We process your personal data for a variety of purposes that are precisely defined, legitimate and proportionate, and for which the legal bases are as follows: compliance with our legal and regulatory obligations, your consent, the performance of a contract with you or for our legitimate interest.

In accordance with the Regulation, the personal data we collect are used for the purposes for which they were collected and for the time strictly necessary to achieve the objectives of the processing. This retention period depends on the nature of the processing and its purposes.

At the end of the retention periods, we delete your personal data with the exception of data that we are legally obliged to retain or that is necessary to safeguard our rights, which is kept in an archive for the periods necessary to comply with our legal obligations or to safeguard our rights, and then deleted at the end of these periods.

• Management of your account and follow-up of the customer relationship:

We process your personal data to manage your account and to maintain our relationship.

The creation of an account is necessary to access Winamax Offers and to use the services offered by the Application. In order to obtain validation of your account, you must provide the personal data required at the time of its creation.

WINAMAX is legally required to verify that the personal data provided by its players are accurate, complete and, if necessary, kept up to date. We can be brought, at any time, to ask you a verification of the conformity of these data and/or ask you for additional information.

In this respect, we process your data in the context of your requests and complaints made to our customer service department. The messages you send us may be recorded and analysed to process your requests and complaints and to improve the quality of our offers and services.

This data processing is also used to manage your customer account, the WINAMAX loyalty program, and the realization of satisfaction surveys and / or studies and statistics.

Finally, with your consent, your bank details may be stored to facilitate payment transactions. Your bank account number (IBAN) will be used to pay out your winnings and keep track of your player account balance. Your credit card information is used to deposit money into your player account. You can manage the storage and deletion of these bank details in your player account at any time in the "My Account" tab. Your credit card information is only collected by our PCI-DSS (banking security standard) certified payment service provider, which ensures the security of payments.

• Management of commercial offers and personalization of services:

You have the possibility to configure and choose to receive commercial offers, newsletters and news from WINAMAX on different communication channels (email, mobile notification, etc.), according to your preferences, directly in the tab "My Account - Communication preferences".

Subject to your choices, we may process your personal data to enable us to determine your player profile and to provide you with personalized commercial offers, newsletters and certain loyalty benefits based on your playing habits.
We may also deliver loyalty rewards to your mailing address, where eligible.

You may object at any time to receiving these commercial offers, newsletters and personalized news or change your choices from the "My Account - Communication Preferences" tab.

• Use of the Site:

We process your personal data to enable you to use and navigate our Site.

The processing implemented for this purpose allows us to identify you as a user of the Site and to manage any communications you send us from the Site.

In addition, your navigation on the Site leads to the deposit and reading of cookies essential to the functioning of the Site, which are not subject to obtaining your consent. You can find out more about cookies and how to manage their storage on your mobile device in the "Cookies - Cookie management" section.

• Use of the Application:

We process your personal data when you connect to the Application from a mobile device for the purpose of managing your online account and our relationship, but also for the purpose of personalizing our services and receiving our commercial offers, newsletters and news that you have consented to receive, or for the purpose of conducting studies and statistics.

Depending on the configuration of your mobile device and your choices, you may be able to benefit from geo-located services and commercial offers.

• Social networks:

We may collect some of your personal data in the course of your interactions with our pages and accounts on social networks, particularly when you communicate with us directly on these platforms.

However, these platforms are managed by third-party companies and we have no control over the management and use of your data by these platforms. We recommend that you read the privacy policies of these platforms.

• Fight against fraud, money laundering and terrorist financing :

As part of the fight against fraud, money laundering and the financing of terrorism, we implement tools for monitoring and tracking players to detect risky behaviour. These solutions also allow us to prevent identity theft and fraud. They are based on the use of algorithms and decision-making processes that always require human intervention.

• Preserving gambling integrity :

In order to preserve the player experience and combat prohibited practices within the meaning of our game rules and general terms and conditions, we implement control systems and processes involving the processing of your personal data. These tools enable us to detect players likely to cheat and contravene the rules, for example by using bots, or by teaming up with other players to distort game results.

• Combating problem gambling and promoting responsible gambling

As part of the prevention and fight against excessive gambling, we are implementing player monitoring tools to detect suspicious or risky behaviour. The use of algorithmic solutions aims to identify players likely to develop addictive and excessive behaviour, in particular by analysing the time spent playing, the frequency of deposits, the nature and volume of bets, the location and IP addresses of the terminals used. However, no decision is made without human intervention. These solutions allow us to comply with our legal obligations.

As part of the responsible gaming promotion, we ask you to set monthly and weekly deposit limits. If you reach the limits you have previously set, we will automatically block the deposit of funds to your account (automated individual decision).
In order to meet the objective of combating problem gambling and in accordance with our legal obligations, we are required to check with the relevant authorities to ensure that you are not on the list of people banned from gambling managed by the ANJ.

HOW LONG DO WE KEEP YOUR DATA?

In the context of the above-mentioned processing, we store your personal data in the manner described in the table below:

This data is always kept secure and is only accessible to those authorized to do so.

WHO WILL RECEIVE YOUR DATA?

In order to achieve the purposes described above and only to the extent necessary for the pursuit of those purposes, the personal data we collect may be transferred to some or all of the following recipients:

• WINAMAX's subcontractors, including technical service providers and payment institutions, to the extent necessary to accomplish the missions we entrust to them (we require our subcontractors to apply strict rules and measures to achieve a level of guarantees for the protection of your data in accordance with the Regulations);
• WINAMAX's partner companies subject to your prior agreement;
• The authorities and in particular the ANJ, as the regulator of the sector of gambling and games of chance under exclusive rights, as well as online games, is likely to obtain the transmission of your personal data in order to carry out the missions defined by the law n°2010-476 of 12th May 2010 relating to the opening to competition and the regulation of the sector of online gambling and games of chance, in particular in regards to the fight against excessive gambling, in the exercise of the prerogatives that the law assigns to it

SECURITY OF YOUR DATA

We take all precautions and technical, physical and organizational measures to ensure the security and confidentiality of your data, in particular to prevent their loss, alteration, destruction or use by unauthorized third parties.

In addition, WINAMAX requires its subcontractors to implement appropriate technical and organizational security measures to ensure the confidentiality of personal data and a level of security appropriate to the risk.

TRANSFERS OF YOUR DATA

We process and store your data within the European Union. Therefore, we do not transfer your data outside the European Union.

However, if WINAMAX were to transfer your data outside the European Union, it would take appropriate measures to ensure that your personal data is adequately protected in the target country. In this case, we put in place contractual measures and controls regarding technical and organizational measures that comply with the Regulation to ensure that personal data is processed with the same level of security as required by the European Regulation.

COOKIES AND OTHER TRACKERS

When using our sites and applications, information relating to the navigation of your device (computer, tablet, smartphone, etc.) on the sites and applications may be recorded in text files called "cookies", installed on your browser. Cookies are used to recognize your browser during the validity period of the cookie concerned and to send back to the Site certain information (for example, a session identifier or the choice of a language).

Some cookies may also be used to store the contents of a password, some to store the language settings of a site, and some to provide you with personalized services.

Only the issuer of the cookie concerned is likely to read or modify the information contained therein.

There are different types of cookies:

• Session cookies that disappear as soon as you leave the site;
• Permanent cookies that remain on your device until their lifetime expires or until you delete them using your browser's features.

You are informed that, during your visits to this site, cookies may be installed on your device.

These cookies can come from different issuers:

• WINAMAX cookies: these are cookies that may be deposited by WINAMAX on your terminal during your navigation on our sites and applications. These cookies allow us to personalize and continually improve your experience on our sites and applications;
• Third-party cookies: these are cookies that may be placed by third-party companies (for example, advertising agencies, social networks, partners of WINAMAX, etc.) on your terminal during your navigation on our sites and applications. They allow these third-party companies, during the validity of their cookies, to identify your interests, to collect browsing information relating to the consultation of our sites and applications and to customize advertisements likely to correspond to your interests and your user profile, which you may be exposed to on our sites and applications.

When you first visit our Site, you will be asked to accept or refuse the use of certain cookies.

If you do not want cookies to be installed or read on your terminal equipment, a cookie of refusal will be deposited on it, so that WINAMAX records the information that you opposed the use of cookies. If you delete this refusal cookie, it will no longer be possible to identify you as having refused the use of cookies.

Similarly, when you accept the cookies, a consent cookie is set.

The refusal or consent cookies must remain on your device. You can modify your choices at any time using the cookie management tool in the "Cookies - Cookie management" section. This cookie management tool allows you to manage and modify the use of cookies at any time. You can also manage cookies from your browser settings.

In accordance with the Regulations, cookies are kept for a period of 13 months.

You can also exercise your choices with third-party cookie issuers:

    - Audience measurement and content improvement cookies:

These cookies allow us to measure the number of visitors to our Site and Application and the performance of our marketing operations in order to improve content and services for all users.

Google's privacy policy is available via the following link: https://policies.google.com/privacy?hl=en.

    - Advertising optimization cookies:

These cookies enable us to present advertising tailored to each player's interests, with the help of our partners. These cookies also enable us to measure the effectiveness of our advertising campaigns.

Rejecting these cookies will not stop advertising on our Site and Application or on other sites you visit. Advertisements will simply no longer be personalized and may therefore be less interesting for you.

The privacy policies of third-party cookie issuers regarding advertising optimization are available via the following links:

• Google : https://policies.google.com/technologies/ads?hl=en
• Bing : https://privacy.microsoft.com/en-us/privacystatement
• Meta (Facebook and Instagram) : https://www.facebook.com/policy.php
• Snapchat : https://help.snapchat.com/hc/en-us/articles/7012343074580
• Adjust : https://www.adjust.com/terms/privacy-policy/
• Twitter (X) : https://twitter.com/en/privacy

WHAT ARE YOUR RIGHTS AND HOW DO YOU EXERCISE THEM?

In accordance with the Regulations, you have a certain number of rights set out below which you may exercise as soon as the conditions for their application are met by sending your request to dpo@winamax.fr.

The rights you have are the following:

A right to access
You may obtain a copy of your personal data provided that their transmission does not infringe on the rights and freedoms of third parties, intellectual property rights, business secrecy or the secrecy of correspondence.

A right to rectification
You may request that your data be corrected if it is inaccurate or incomplete.

A right to erasure
You may obtain the deletion of your personal data if:

• Their processing is no longer necessary for the purposes for which we collected them;
• You withdraw your consent when it was the legal basis for the processing;
• You have exercised your right to object where this was applicable;
• The data was processed illegally;
• Data must be deleted to comply with a legal obligation.

A right to limit processing
You may request a temporary "freeze" of the data processing, but only in the cases provided by the Regulations.

A right to portability
You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format, and the right to transmit that data to another data processor when:

• This processing is based on your consent or on a contract;
• This processing is carried out using automated processes.

A right to object
In principle, you have the right to object to the processing of your personal data under the conditions defined by the Regulations. However, pursuant to Article 2 of Decree 2010-518 of 19th May 2010, you are informed that the creation of an account entails the waiver of your right to oppose the processing of your personal data.

If you feel that your rights relating to your personal data have not been respected after having contacted us, you may submit a complaint to the Commission Nationale de l'Informatique et des Libertés (3 place de Fontenoy - TSA 80715 - 75334 Paris cedex 07 - telephone: 01 53 73 22 22).