PRIVACY POLICY

Website and Services Privacy Policy

Effective Date: May 1, 2021

This website is developed and maintained by Vegas Lit Games, LLC (hereinafter "VegasLit," "we," or "us"). The data controller is VegasLit and can be contacted as explained below in the How to Contact Us section. The data protection officer is: S. Brown and she may be reached at info@vegaslit.com

CUSTOMER SERVICE INQUIRIES:

Please note that the above address is for inquires related to the privacy policy and personal data only. You may also use the link found at the end of the policy to submit privacy policy and personal data inquiries. Standard customer service requests should be addressed to info@vegaslit.com When you visit our websites, mobile applications, official social media sites, or other online properties, collectively "Sites" or "Services," VegasLit may collect and use certain information about you. VegasLit recognizes that you care about how your information is used, and your privacy is important to us. This Privacy Policy explains how we may collect and use your information, particularly your personal information, and the choices you can make about what information you share. This Privacy Policy applies to information collected by our Sites and Services, including, but not limited to, all websites and applications that post a link to this Privacy Policy. Please read this Privacy Policy carefully. By continuing to interact with our Sites and Services, you are agreeing to the practices described in this Privacy Policy, as permitted by applicable law. If you are located in the European Union ("EU") or the United Kingdom ("UK"), this Privacy Policy also informs you about the management of your personal data and your rights in accordance with Article 13 of the General Data Protection Regulation ("GDPR"). If you are a resident of California, this Privacy Policy also informs you of certain privacy rights under California law.

UPDATES TO OUR PRIVACY POLICY

We ask that you read this Privacy Policy from time to time. VegasLit may modify this Privacy Policy at any time in its sole discretion. If we make material changes to this Privacy Policy that increase our rights to use personal information we have previously collected about you, or if we intend to process your personal data for a purpose other than that for which the personal data was first collected, we will provide you with additional information necessary to ensure fair and transparent processing and obtain your consent where required by law.

INFORMATION WE COLLECT

VegasLit collects information about you when you interact with our Sites and Services. When you use our Sites and Services, we collect information about one or more devices associated with you that you use to access the Sites, such as a computer, mobile phone, or tablet.

Information collected solely from playing our games: We collect, store, and use information you provide to us from one or more devices associated with you when you play our games (which comprise a portion, but not all, of the Services), including when you log into a game or register for an account from one or more of your devices, or otherwise interact with us through the Apps that make up the Services. Information that we collect when you play our games includes your device ID, language, game preferences and general geolocation.

Information collected from websites:
We collect, store, and use information you provide to us from one or more devices associated with you when you use our Sites, including when you log into the Sites or Services from one or more of your devices, register for an account, complete a web form or post on our website, make a purchase, add or update your account information, make a customer service request or send us a customer service email, or otherwise correspond with us regarding the Sites. Information that we collect, when you provide it to us, includes your name, physical address, country of residence, email address, telephone number, language, age, gender, and employment history information. We collect your social media information or profile, such as your application-specific Facebook ID, first name, last name, middle name, short name, and profile picture if you sign in with your Facebook account. In addition, when you make a purchase through our Sites, a third-party payment processor will collect your billing information, such as payment card information.

INFORMATION WE AUTOMATICALLY COLLECT

We automatically collect information about the devices you use to interact with our Sites. We automatically collect your device identifier, web browser type and version, IP address, general geolocation, language, and browsing information collected through cookies and beacons. We also automatically collect information about how you use the Sites, such as what you have searched for and viewed on the Sites. The information automatically collected will be associated with any personal information you have provided.
We collect certain information by automated means when you visit our Sites, such as how many users visited our Sites and the pages accessed. By collecting this information, we learn how to best tailor our Sites to our visitors.

• Cookies.
• Like many companies, we use "cookies" on some of our Sites. Cookies are pieces of code placed on your devices when you visit certain websites. We use cookies to tell us, for example, whether you have visited us before or if you are a new visitor, and to help us identify features of the Sites in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are visiting a particular website. Most web browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of the features and functionality of the Sites.
• Web Beacons.
• Certain pages on our website contain "web beacons" (also known as Internet tags, pixel tags, and clear GIFs). These web beacons allow third parties to obtain information, such as the IP address of the computer that downloaded the page on which the beacon appears; the URL of the page on which the beacon appears; the time the page containing the beacon was viewed; the type of browser used to view the page; and the information in cookies set by the third party.
• IP Addresses.
• An IP address is a unique identifier that certain electronic devices use to identify and communicate with each other on the Internet. When you visit our website, we view the IP address of the device you use to connect to the Internet. We then use this information to determine the general physical location of the device and understand the general locations of our website visitors. We also use this information to enhance our Sites.

HOW WE USE THE INFORMATION WE COLLECT ABOUT YOU

We may use your information for the following purposes:

• To Communicate With You
• To provide you with customer support;
• To process your purchases and transactions;
• To communicate with you about our products and services, including promotions, solicitations and offers; or
• To send you further notices, or other marketing materials regarding our Sites, our products, and the services of our businesses, affiliates, or business partners.
• To Manage and Improve Our Business Operations
• To provide you with access to the Services;
• To provide you with access to the Services;
• To serve the functions of the Sites;
• To manage everyday business needs, such as administering and improving the Sites;
• To analyze and improve the performance and functioning of the Sites;
• To analyze how you use the Sites and to perform other market research;
• For internal operations, including troubleshooting, testing and analytics;
• To tailor content on the Sites and target our advertising;
• For compiling aggregated and de-identified information; and
• To assist us in developing new products and improving our Services.
• To Ensure a Secure Online Environment and Comply with Legal Obligations
• To protect against and detect fraud, abuse, or other unlawful activity;
• To enforce our Terms of Service, other corporate policies, and industry standards; and
• To comply with all applicable laws and reporting obligations.

If you notify us that you do not wish to be contacted for marketing purposes, we will not send you marketing information. To opt out of receiving our promotional emails or if you object to our use of your information for direct marketing purposes, please unsubscribe via the links contained in the emails you receive from us or submit a request using our Privacy Rights Request form linked at the end of this policy.

DO NOT TRACK

Our Sites do not collect personal information about your online activities over time and across third-party websites or online services. Therefore, "do not track" signals transmitted from web browsers do not apply to our Sites, and we do not alter any of our data collection and use practices upon receipt of such a signal.

BUSINESS STRUCTURE CHANGES

We reserve the right to disclose and transfer all information related to our Sites, including personal data:

• To a subsequent owner, co-owner, or operator of one or more of the Sites; or
• In connection with a corporate merger, consolidation, or restructuring, the sale of substantially all of our stock and/or assets, or other corporate change, including, without limitation, during the course of any due diligence process.

INFORMATION WE SHARE

We share information within the VegasLit family of companies, including future subsidiaries and affiliates.
We share your information with service providers who perform services and functions on our behalf to support our interactions with you including, for example, providing our products and services, or communicating with you. We also share information with companies that operate our websites and third party analytics companies who conduct market research on our behalf. These service providers are not authorized by us to use or disclose the information, except as necessary to perform services on our behalf or comply with legal requirements.
As part of our Sites and Services, third party ad servers present or serve advertisements, provide us with reporting, ad response management, and Site analytics, and assist with delivery of relevant marketing messages and advertisements. These third parties may view, edit, or set their own cookies. The use of these technologies by these third parties is subject to their own privacy policies and is not covered by this Privacy Policy. Third parties may also obtain information about other sites you have visited or applications that you have downloaded to your mobile device, and other information about you or your device in order to help analyze and serve anonymous targeted advertising on the Site and elsewhere.
VegasLit also shares limited geolocation information with third parties, including advertisers who provide targeted advertising and analytics services. We may also share aggregated or de-identified information with third parties that does not identify you personally.

In addition, we will disclose information about you:

• If we are required to do so by law or legal process;
• To law enforcement authorities or other government officials, as necessary;
• When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or suspected or actual illegal activity;
• If necessary to protect the vital interests of a person;
• To enforce our Terms of Service;
• To protect our property, services, and legal rights;
• To prevent fraud against VegasLit, our affiliates, business partners, or authorized dealers;
• To support auditing, compliance, and corporate governance functions; or
• To comply with any and all applicable laws.

In certain situations, VegasLit may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

CHILDREN'S PRIVACY

Our sites are general audience Sites not directed at children under the age of 18. If we obtain actual knowledge that any information we collect has been provided by a child under the age of 18, we will promptly delete that information and disable the associated account.

LINKS TO OTHER WEBSITES

Our Sites may provide links to other websites for your convenience and information, including those that are operated by third parties. Third party websites may operate independently from our Sites, which means we are not responsible for their content, how they use your information, or their privacy practices.

INFORMATION WE TRANSFER

The Sites to which this Privacy Policy applies are subject to United States law, unless otherwise provided herein. VegasLit ensures that all personal data from individuals in the European Union is processed in accordance with the General Data Protection Regulation. All cross-border transfers are made through an approved transfer mechanism—such as our Intra-Group Data Transfer Agreement or Standard Contractual Clauses, or with your explicit consent. VegasLit's agreements and clauses may be requested by contacting info@vegaslit.com.
In addition, we transfer the personal information we collect on the Sites to countries other than the United States where we do business, which may not have the same data protection laws as the country in which you reside. When we transfer your information to other countries, we will protect that information as described here, even though a given country may not have the same privacy and data protection laws as the country in which you reside.
VegasLit complies with the EU-U.S. Privacy Shield Framework and/or the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and/or Switzerland to the United States. VegasLit has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, VegasLit is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). In compliance with the Privacy Shield Principles, VegasLit commits to resolve complaints about our collection or use or your personal information. The independent dispute resolution body designated to address complaints and provide appropriate recourse free of charge is JAMS. European Union and/or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact VegasLit at info@vegaslit.com.
VegasLit is responsible for the processing of personal data it receives under the Privacy Shield Framework or subsequently transfers to a third party acting as an agent on its behalf, except where VegasLit is not responsible for the event giving rise to the damage.
If you have any questions or concerns regarding our Privacy Shield certification, please contact info@vegaslit.com.

CALIFORNIA RESIDENTS

If you are a California Resident, California law provides you with certain rights regarding your personal information, including the right to know about personal information collected, disclosed, or sold. You also have the right to request that we delete any or all of your personal information that we have collected from you, subject to certain exceptions, and the right not to be discriminated against if you exercise any of your rights under the California Consumer Privacy Act. VegasLit may have collected the following categories of personal information from California residents in the past 12 months:

• Identifiers such as a name, postal address, IP address, email address, or other similar identifiers.
• Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80.
• Characteristics of protected classifications under California or federal law.
• Commercial information, including records of products or services purchased or considered.
• Internet or other electronic network activity information.
• Geolocation data.
• Professional or employment-related information.
• Education information.
• Inferences drawn from any of the information identified above.

We collect this personal information from a number of sources, including from you directly and from consumer data resellers, and use it for the purposes disclosed in this Privacy Policy. We may have disclosed the categories of personal information identified above to certain third parties for a business purpose over the past twelve months, including internet service providers, data analytics providers, government entities, operating systems and platforms, and social networks. Where we disclose information for a business purpose, we enter into a contract that describes the business purpose and requires the recipient to keep the personal information confidential and not use it for any purpose except for performing the contract. VegasLit will not and has not sold personal information of California residents, including those under 16 years of age, to third parties for a commercial purpose in the preceding twelve months.

Right to Know
California residents have the right to request that VegasLit disclose certain information about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Requests to Know and Delete below for instructions), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.

Right to Delete
You have the right to request that VegasLit delete the personal information that we collected from you and retain, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Requests to Know and Delete below for instructions), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Requests to Know and Delete
To exercise your right to know and right to delete described above, please submit a verifiable consumer request to us using our Privacy Rights Request form found at the end of this policy or you can e-mail us at info@vegaslit.com.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. If you wish to submit a verifiable consumer request on behalf of another individual, we will also need sufficient information to verify that the individual is the person about whom we collected personal information and that you are authorized to submit the request on their behalf.
You may only make a verifiable consumer request to know or delete your data twice within a 12-month period. Your request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or are an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will need to verify your identity before processing most requests, which may require us to obtain additional personal information from you. We will only use the personal information provided in connection with a request to review and comply with the request. If you do not provide this information, we may not be able to verify or complete your request.
Making a verifiable consumer request does not require you to create an account with us.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason for the extension.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. For data portability requests, we will select a format to provide your personal information that is readily useable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. In certain circumstances, we may decline a request to exercise the rights described above. California Civil Code Section 1798.83 permits California residents to request information regarding the disclosure of their personal information by us to third parties for the third parties' direct marketing purposes within the immediately preceding calendar year. We will provide you with a list of the categories of personal information disclosed and a list of the names and addresses of the third parties. To make such a request, please fill out our Privacy Rights Request form below and select "Shine the Light" the dropdown menu.

NEVADA RESIDENTS

VegasLit does not sell personal information of Nevada residents to third parties; however, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us using our Privacy Rights Request form and make sure you include the words "Nevada opt-out" in the "Request Details" section of the request form.

YOUR RIGHTS IF YOU ARE LOCATED IN THE EU, SWITZERLAND OR UK

If you are located in the EU, Switzerland or the UK, we process your personal data when we have a legal basis to do so. We will rely on the following legal bases for processing your personal data, depending on our purpose for such processing.

Legal Basis for Processing
You have consented to the processing of your personal data: We will obtain your consent before using or sharing your data for advertising that is targeted based on your browsing history or online behavior on other websites or online services. If you consent to our use of your personal data for any purpose, you have the right to withdraw consent at any time by contacting us, as explained below.
Processing is necessary to fulfill a legitimate interest: We have a legitimate interest in processing your personal data for certain business and security purposes, to better understand our customers and the users of our Sites and Services, and to comply with applicable laws.
Processing is necessary for compliance with a legal obligation: We will process personal data when necessary to comply with an obligation under EU law, EU Member State law or, with respect to individuals residing in Switzerland, a Swiss law.
Processing is necessary to perform a contract: We will process personal data when necessary to perform a contract with you or to fulfill a request you have made.

Your Rights Regarding Your Personal Data
In addition, you have certain rights with respect to your personal data, subject to exceptions as provided in the GDPR. If you would like to exercise any of the rights described below, please use the Privacy Rights Request form found at the end of this policy or through one of the methods in the "Contact For More Information" section, below.

• Right of Access: You have the right to obtain confirmation as to whether we are processing personal data about you, and if so, to request a copy of the information. To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your information.
• Right to Rectification: You have the right to correct any inaccuracies in the information that we hold about you and, where applicable, complete any incomplete information that we hold.
• Right to Erasure: You have the right to request that we erase personal information that we hold about you, subject to certain conditions.
• Right to Restrict Processing: You have the right to restrict our processing of your information, subject to certain conditions.
• Right to Object: You have the right to object to processing of your personal information based on our legitimate interests at any time. We will no longer process the information, unless there are compelling legitimate grounds for our processing that override your interests or the processing serves the purpose of asserting, exercising, or defending legal claims.
• Right to Withdraw Consent: When data processing is based on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before such withdrawal.
• Right to Data Portability: You also have a right to data portability when the data processing is based on consent or on a contract between you and VegasLit and the data was processed by automated means. You may exercise these rights by submitting a written request at the link included below.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the appropriate supervisory authority or data protection regulator in your jurisdiction.

HOW WE PROTECT PERSONAL INFORMATION

We use commercially reasonable security measures, including administrative, technical, and physical safeguards to protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information you provide when visiting or using the Sites.

RETENTION OF INFORMATION

VegasLit retains all personal information for the duration of the relevant business relationship or, where required, in accordance with its information management policies and schedules, subject to applicable laws. When deleting personal information based on a request from the individual to whom the information relates, VegasLit will make reasonable attempts to ensure that all instances of the information are deleted in their entirety. For individuals in the EU, Switzerland or U.K. who wish to make requests for access, corrections, or deletion, please refer to the Your Rights Regarding Your Personal Data section above.