Privacy Policy

Privacy and Cookie Policy

Version 1.

Last revised: February 18, 2023
Effective date: February 18, 2023

Altura Gaming Co. and its affiliates (“Altura” or “we,” including derivative terms) is
committed to safeguarding your privacy. This Privacy and Cookie Policy (the “Policy”)
describes our policies and procedures regarding the collection, use and disclosure of
information we obtain through the website at , applications created
by users and hosted by Altura (“Altura Applications”), the marketplace we operate for the
convenience of our users that lets them license games and other applications from each
other (“Direct User Content”), application building, hosting, and management products
(“Development Tools”), and any other online or Web3 services we may provide (all the
above, collectively, the “Altura Platform”). Please read the following information carefully
to understand our views and practices regarding your personal data and how we will treat
it.

¡£DEFINITIONS

As used in this Policy, a “Direct User” is an individual who has an cryptocurrency wallet
connected to the Altura Platform and can build Altura Applications, and an “End User” is an
individual who uses an Altura Application. Except where specified below, this Policy applies
equally to both Direct and End Users.

Ô£PARTICULARLY IMPORTANT INFORMATION

WHO WE ARE. For the purpose of applicable data protection legislation, the data
controller of your personal data is Altura Gaming Co., a Delaware corporation.MUST READ
SECTIONS: We draw your attention in particular to the sections entitled “INTERNATIONAL
DATA TRANSFER” and “YOUR RIGHTS.” CHANGES TO THIS POLICY: We will post any
modifications or changes to the Policy on the Altura Platform. We reserve the right to
modify the Policy at any time, so we encourage you to review it frequently. The “Last
Revised” legend above indicates when this Policy was last changed. If we make any
material change(s) to the Policy, we will notify you via email or post a notice on our Site prior
to such change(s) taking effect.

Privacy and Cookie Policy

9:LEGAL BASES FOR PROCESSING EU PERSONAL DATA

We use your personal information only as permitted by law. Our legal bases for processing
the personal data described in this Policy are as followsQ

:HOW WE COLLECT YOUR INFORMATION

Information You Provide.

We collect personal data from Direct Users when they register to use the Altura Platform,
post content on the Altura Platform, or communicate with us (e.g., through the “Contact”
page on our site, or when requesting customer service or technical support), make
purchases through the Altura Marketplace, or provide us with feedback about the Altura
Platform. We may also collect personal data at other points in the Altura Platform when
clearly identified.

Privacy and Cookie Policy

We do not collect personal data directly from End Users unless they contact us (i.e.,
through the “Contact” page on our site or to provide feedback about the Altura Platform).
Each individual operator of a Altura Application determines what End User information is
required to operate their Altura Application, is required to comply with all applicable laws
respecting the treatment of such information and is responsible for all use of such
information. However, because Altura Applications run on our infrastructure, the
“Information Collected via Technology” section below applies equally to End Users and
Direct Users.

Registration. To create an account, Direct Users need to connect a cryptocurrency wallet
to the Altura Platform. Direct Users may provide other optional information, such as profile
photos, their location, or job title, and email address. Direct Users may always go to the “My
account” section of the Altura Platform to update, change, or remove their information.

Altura Sites. We do not collect or use End User personal data, except to provide customer
support, respond to direct requests, or as automatically collected through technical
means as set forth below. As noted above, the operators of Altura Sites may collect and
use the information of End Users of their sites, including personal data and content posted
to Altura Sites. Altura does not control or monitor such collection and usage.

Altura Marketplace. We do not collect any personal data in the course of operating the
Altura Marketplace, but in order to make available or license User Components on the
Altura Marketplace, you must be a Direct User who has connected a cryptocurrency wallet
to the Platform. Certain Direct User account information (including account name or other
personal data) may be made available to the buyer and seller involved in a Altura
Marketplace transaction. Altura does not control or monitor the use of such information by
participants in a Altura Marketplace transaction.

Information Collected via Technology.

Information Collected by Our Servers. To make the Altura Platform more useful to you, our
servers (which may be hosted by a third party service provider) collect information from
you, which may include your browser type, operating system, Internet Protocol (“IP”)
address (a number that is automatically assigned to your computer when you use the
Internet, which may vary from session to session), domain name, and/or a date/time stamp
for your visit.

Privacy and Cookie Policy

Log Files. As is true of most websites, we gather certain information automatically and
store it in log files. This information may include IP addresses, browser type, Internet
service provider (“ISP”), referring/exit pages, operating system, date/time stamp, data
typed into the site, and clickstream data. We use this information to analyze trends,
administer the Altura Platform, track users’ movements around the Altura Platform, gather
demographic information about our user base as a whole, and better tailor the Altura
Platform to our users’ needs. For example, certain information may be collected so that
when you visit the Altura Platform again, it will recognize you and remember preferences
(such as previous User Components viewed or licensed from the Altura Marketplace).
Except as noted in this Policy, we do not link this automatically-collected data to personal
data.

How We Respond to Do Not Track Signals. We do not currently respond to “do not track”
signals or other mechanisms that might enable you to opt out of tracking on our site. To find
out more about “do not track,” please visit http://www.allaboutdnt.com.

Mobile Services. We may also collect non-personal data from your mobile device if you
access the Altura Platform from your mobile device. This information is generally used to
help us deliver the most relevant information to you. Examples of information that may be
collected and used include your geographic location and information about the type of
device you use. In addition, if the Altura Platform crashes on your mobile device, we may
receive information about your mobile device model software version and device carrier,
which allows us to identify and fix bugs and otherwise improve the performance of the
service. This information is sent to us as aggregated information and cannot be used to
identify an individual.

Analytics Services. In addition to the tracking technologies we place, other companies
may set their own Cookies or similar tools when you use the Altura Platform. This includes
third party analytics services, such as Google Analytics (“Analytics Services”), that we
engage to help analyze how users use the Altura Platform, as well as third parties that
deliver content or offers. We may receive reports based on these parties’ use of these
tools on an individual or aggregate basis. We use the information we get from Analytics
Services only to improve the Altura Platform. The information generated by the Cookies or
other technologies about your use of the service (the “Analytics Information”) is
transmitted to the Analytics Services. (Cont.)

Privacy and Cookie Policy

The Analytics Services use Analytics Information to compile reports on user activity. The
Analytics Services may also transfer information to third parties where required to do so by
law, or where such third parties process Analytics Information on their behalf. Each
Analytics Services’ ability to use and share Analytics Information is restricted by such
Analytics Services’ Terms of Use and Privacy Policy. By using the Altura Platform, you
consent to the processing of data about you by Analytics Services in the manner and for
the purposes set out above. We may also partner with ad companies to support our
marketing efforts, including by serving you ads better tailored to your likely interests. If you
don’t want to take advantage of these services, you can opt-out by visiting
or , or if you are located in
the EU, .

http://
http://www.aboutads.info/ http://networkadvertising.org/choices/
http://www.youronlinechoices.eu/

SNS Log In. Direct Users may use certain social media site (“SNS”) credentials to log into
the Altura Platform. In such case, we collect personal data from the social media website.
For example, when you log in with your Google credentials, we may collect the personal
data you have made publicly available in Google, such as your email address, name, and
profile picture or logo. You agree that you are solely responsible for your use of an SNS and
that it is your responsibility to review the terms of use and privacy policy of such SNS. Any
information that we collect from an SNS account will depend on the privacy settings you
have with that SNS, so please consult the SNS’ privacy and data practices. We will not be
responsible or liable for: (a) the availability or accuracy of such SNS; (b) the content,
products or services on or availability of such SNS; or (c) your use of any such SNS. You can
revoke our access to this information anytime by amending the appropriate settings from
within your account settings on the applicable SNS.

Privacy and Cookie Policy

Like many online services, we use Cookies to collect information. “Cookies” are small
pieces of information that a website sends to your computer’s hard drive while you are
viewing the website. We may use both session Cookies (which expire once you close your
web browser) and persistent Cookies (which stay on your computer until you delete them).
We use two broad categories of Cookies: (1) first party Cookies, served directly by us to
your computer or mobile device, which are used only by us to recognize your computer or
mobile device when it revisits the Altura Platform; and (2) third party Cookies, which are
served by service providers on the Altura Platform, and can be used by such service
providers to recognize your computer or mobile device when it visits other websites.Altura
uses Cookies to verify that you are properly signed in, to display information for your
primary location, and to provide information about your Altura Sites (if applicable). We may
also use Cookies from time to time to measure your response to new aspects of the Altura
Platform and/or emails in an effort to continually improve customer service and the Altura
Platform. Please be aware that a Cookie cannot spread computer viruses, retrieve any
other data from your hard drive, or capture your email address.

Cookies we use. The Altura Platform uses the following types of Cookies for the purposes
set out below.

a. Essential Cookies. These Cookies are essential to provide you with services available
through our Services and to enable you to use some of its features. For example, they allow
you to log in to secure areas of our Services and help the content of the pages you request
load quickly. Without these Cookies, the services that you have asked for cannot be
provided, and we only use these Cookies to provide you with those services.

b. Functionality Cookies. These Cookies allow our Services to remember choices you
make when you use our Services, such as remembering your language preferences,
remembering your login details and remembering the changes you make to other parts of
Services which you can customize. The purpose of these Cookies is to provide you with a
more personal experience and to avoid you having to re-enter your preferences every time
you visit our Services.

Privacy and Cookie Policy

c. Analytics and Performance Cookies. These Cookies are used to collect information
about traffic to Services and how users use our Services. The information gathered does
not identify any individual visitor. The information is aggregated and anonymous. It
includes the number of visitors to our Services, the websites that referred them to our
Services, the pages they visited on our Services, what time of day they visited our Services,
whether they have visited our Services before, and other similar information. We use this
information to help operate our Services more efficiently, to gather broad demographic
information and to monitor the level of activity on our Services. We use Google Analytics
and other third party analytics services for this purpose. Google Analytics uses its own
cookies. They are only used to improve how our Services works. You can find out more
information about Google Analytics Cookies here:

. You can find out more about how
Google protects your data here:. You can
prevent the use of Google Analytics relating to your use of our Services by downloading
and installing the browser plugin available via this link:
.

d. Social Media Cookies. These Cookies are used when you share information using a
social media sharing button or “like” button on our Services or you link your account or
engage with our content on or through a social networking website such as Facebook,
Twitter, or Google+. The social network will record that you have done this.

https://developers.google.com/
analytics/resources/concepts/gaConceptsCookies
http://www.google.com/analytics/learn/privacy.html

http://tools.google.com/dlpage/
gaoptout?hl=en-GB

Disabling Cookies. You can typically remove or reject Cookies via your browser settings. In
order to do this, follow the instructions provided by your browser (usually located within
the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept Cookies
until you change your settings. Further information about Cookies, including how to see
what Cookies have been set on your computer or mobile device and how to manage and
delete them, visit and Direct
Users must accept Cookies in order to access certain features of the Altura Platform. You
can erase or block Cookies from your computer if you wish to do so (your internet browser
help screen or manual will thoroughly explain this process), but certain parts of the Altura
Platform will not work correctly or at all if your browser is set to not to accept Cookies.

Privacy and Cookie Policy

https://developers.google.com/
analytics/resources/concepts/gaConceptsCookies
http://www.google.com/analytics/learn/privacy.html

http://tools.google.com/dlpage/
gaoptout?hl=en-GB

Privacy and Cookie Policy

Pixels

We may also use pixel tags (which are also known as web beacons and clear GIFs) on the
Altura Platform to track the actions of users on our Services. Unlike Cookies, which are
stored on the hard drive of your computer or mobile device by a website, pixel tags are
embedded invisibly on webpages. Pixel tags measure the success of our marketing
campaigns and compile statistics about usage of the Altura Platform, so that we can
manage our content more effectively. With the exception of the Facebook Pixel (see
below), the information we collect using pixel tags is not linked to our users’ personal data.

Altura may use the Facebook Pixel to gather information about your activities on the Altura
Platform in order to provide you with tailored Altura ads. For example, if you sign up for
Altura, you may see a Altura ad on your Facebook newsfeed. Facebook’s use of
information collected is set forth in its Privacy Policy
). You may opt out of Facebook’s interest-based ads here (
).

Automated decision-making or profiling

We do not use your personal data for the purposes of automated decision-
making. However, we may do so in order to fulfill obligations imposed by law, in which case
we will inform you of any such processing and provide you with an opportunity to object.

(https://www.facebook.com/
policy.php https://
http://www.facebook.com/about/ads/#

6. HOW ALTURA USES YOUR INFORMATION

Personal Data. In general, we use personal data either to deliver the Altura Platform or
respond to requests that you make. We use your personal data in the following ways
facilitate the creation and securing of your account (Direct Users only);±
identify you as a user of the Altura Platform;±
operate, maintain, and provide improved administration of the Altura Platform
improve the quality of experience when you interact with the Altura Platform;±
manage your account, including to send you administrative e-mail notifications, such
as security or support and maintenance advisories (Direct Users only);

Privacy and Cookie Policy

6. HOW ALTURA USES YOUR INFORMATION

Anonymous Data. We may create anonymous data about both Direct Users and End User
by excluding information (such as your name) that makes the data personally identifiable to
you. We use this anonymous data to analyze request and usage patterns so that we may
enhance the content of the Altura Platform. We may use anonymous data and aggregated
and other de-identified information for any purpose and disclose anonymous data to third
parties in our sole discretion.

7. HOW ALTURA MAY SHARE YOUR INFORMATION

With Third Parties designated by you. We may share your personal data with third parties
where you have provided your consent to do so. (Cont.)

Privacy and Cookie Policy

7. HOW ALTURA MAY SHARE YOUR INFORMATION (Cont.)

With Third Parties. We may share your personal data with third party service providers
(“Subprocessors”) to provide you with the Altura Platform, to conduct quality assurance
testing, to facilitate creation of accounts, to provide technical support, to conduct data
analysis, to process payments, to provide information technology and related
infrastructure provision, customer service, email delivery, and/or to provide other services.
These Subprocessors are only permitted to use your personal data to the extent necessary
to enable them to provide their services to us. They are required to follow our express
instructions and to comply with appropriate security measures to protect your personal
data.

Posting on the Altura Platform. You may share personal data with us when you submit user
generated content to the Altura Platform, including via user forums or reviews of Direct
User Content within the Altura Marketplace. Please note that any information you post or
disclose on the Altura Platform will become public information, and will be available to
other users of the Altura Platform and to the general public.

We urge you to be very careful when deciding to disclose your personal data, or any other
information, on the Altura Platform. Such personal data and other information will not be
private or confidential once it is published on the Altura Platform. Altura is not responsible
for how others use such information. If you post personal data, even if you later remove it,
other individuals who saw that personal data may retain copies of it through other means
than the Altura Platform. We or our Direct Users may occasionally reproduce, publish, and
distribute content from reviews in the Altura Marketplace in any forum.

If you provide feedback to us, we may use and disclose such feedback on the Altura
Platform, provided we do not associate such feedback with your personal data. If you have
provided your consent to do so, we may post your first and last name along with your
feedback on the Altura Platform. We will collect any information contained in such
feedback and will treat the personal data in it in accordance with this Policy.

Privacy and Cookie Policy

7. HOW ALTURA MAY SHARE YOUR INFORMATION (Cont.)

With SNS. The Altura Platform or an Altura Application may also enable you to post content
to an SNS. If you choose to do this, we will provide information to such SNS in accordance
with your elections. You agree that you are solely responsible for your use of an SNS and
that it is your responsibility to review the terms of use and privacy policy of such SNS.

As Required by Law. We may access, preserve, and disclose your personal data, other
account information, and content if we believe doing so is required by law or if those
actions are reasonably necessary to:

•comply with legal process, such as a court order or subpoena;

enforce this Policy or our Terms of Service;
respond to claims that any content violates the rights of third parties;
respond to law enforcement;
investigate and prevent unauthorized transactions or other illegal activities; or
protect our or others’ rights, property, or personal safety.

Corporate Events. If we are involved in a merger, acquisition, financing due diligence,
reorganization, bankruptcy, receivership, sale of company assets, or transition of service
to another provider, your information may be sold or transferred as part of such a
transaction. We cannot control how such entities may use or disclose such information.

Other Disclosures. We may share personal data as we believe necessary or appropriate: (a)
to comply with applicable laws; (b) to comply with lawful requests and legal process,
including to respond to requests from public and government authorities; (c) to enforce
our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or
others.

We may also disclose your personal data with your permission.

Privacy and Cookie Policy

8. THIRD PARTY SITES

The Altura Platform may contain links to third party websites and features. This Policy does
not cover the privacy practices of such third parties. These third parties have their own
privacy policies and we do not accept any responsibility or liability for their websites,
features or policies. Please read their privacy policies before you submit any data to them.

9. SECURITY OF YOUR INFORMATION

We seek to use reasonable organizational, technical and administrative measures to
protect personal data within our organization. Unfortunately, no transmission or storage
system can be guaranteed to be completely secure, and transmission of information via
the internet is not completely secure. If you have reason to believe that your interaction
with us is no longer secure (for example, if you feel that the security of any account you
might have with us has been compromised), please immediately notify us of the problem
by contacting us using the details in the Section entitled “CONTACT INFORMATION.” By
using the Altura Platform or providing personal data to us, you agree that we may
communicate with you electronically regarding security, privacy, and administrative issues
relating to your use of the Altura Platform. If we learn of a breach of personal data, we may
attempt to notify you electronically by posting a notice on the Altura Platform or sending
an email to you. You may have a legal right to receive this notice in writing. To receive free
written notice of a security breach (or to withdraw your consent from receiving electronic
notice), please notify us using the details in the Section entitled “CONTACT
INFORMATION.”

10. RETENTION

We will only retain your personal data as long as reasonably required for you to use the
Altura Platform and/or to provide you with the Altura Platform unless a longer retention
period is required or permitted by law (for example, for regulatory purposes).

Privacy and Cookie Policy

11. INFORMATION ABOUT CHILDREN

We do not knowingly collect, maintain, or use personal data from children under 13 years of
age, and no part of the Altura Platform is directed to children under the age of 13. If you
learn that a child has provided us with personal data without your consent, you should alert
us using the details in the Section entitled “CONTACT INFORMATION.” If we learn that we
have collected any personal data about children under 13, we will delete such information
as soon as reasonably practicable.

12. INTERNATIONAL DATA TRANSFER

If you are a non-U.S. user of the Altura Platform or visitor to a Altura Site, by providing us
with data, you acknowledge and agree that your personal data may be processed for the
purposes identified in this Policy. Your information, including personal data that we collect
from you, may be transferred to, stored at and processed by us and other third parties
outside the country in which you reside, including, but not limited to the United States,
where data protection and privacy regulations may not offer the same level of protection
as in other parts of the world. By using the Altura Platform, you agree to this transfer, storing
or processing.

13. SENSITIVE PERSONAL DATA

Subject to the following paragraph, we ask that you not send us, and you not disclose, any
sensitive personal data (e.g., social security numbers, information related to racial or ethnic
origin, political opinions, religion or other beliefs, health, biometrics or genetic
characteristics, criminal background or trade union membership) (“Sensitive Personal
Data”) on or through the Altura Platform or otherwise to us.

Privacy and Cookie Policy

14. YOUR RIGHTS

The following rights may be available to you:

Opt-out. You may contact us anytime to request to opt-out of: (i) direct marketing
communications; (ii) automated decision-making and/or profiling; (iii) our collection of
Sensitive Personal Data; (iv) any new processing of your personal data that we may carry
out beyond the original purpose, where we have requested your consent prior to such
processing; or (v) the transfer of your personal data outside the EEA, where we rely on your
consent for such transfer. Please note that your use of some of the Altura Platform may be
ineffective upon opt-out.
Access. You may request to access the information we hold about you at any time via
your account page or by contacting us directly.
Amend. You can also contact us to request to update or correct any inaccuracies in your
personal data.
Move. You may contact us to request that we move your data to other service providers
as you wish.
Erase and forget. In certain situations, for example when the information we hold about
you is no longer relevant or is incorrect, you can request that we erase your data.

If you wish to exercise any of these rights, please contact us using the details in Section
entitled “CONTACT INFORMATION” below. In your request, please make clear: (i) what
personal data is concerned; and (ii) which of the above rights you would like to request to
enforce. We may deny your request where permitted by applicable law. For your
protection, we may only implement requests with respect to the personal data associated
with the particular email address that you use to send us your request, and we may need to
verify your identity before implementing your request. We will try to comply with your
request as soon as reasonably practicable and in any event, within one month of your
request. Please note that we may need to retain certain information for recordkeeping
purposes and/or to complete any transactions that you began prior to requesting such
change or deletion.

Privacy and Cookie Policy

15. COMPLAINTS

We are committed to resolve any complaints about our collection or use of your personal
data. If you would like to make a complaint regarding this Policy or our practices in relation
to your personal data, please contact us at We will reply to your
complaint as soon as we can and in any event, within 45 days. We hope to resolve any
complaint brought to our attention, however if you feel that your complaint has not been
adequately resolved, you reserve the right to contact your local data protection
supervisory authority.

16. CHANGES TO THIS POLICY

Any changes to this Policy will always be posted to this section of the website, along with
the effective date of the updated Policy. You should check this page periodically to stay
abreast of any such changes. For any material changes to the Policy, we will notify Direct
Users via email or by placing a prominent notice on the homepage of our website.

17. CONTACT INFORMATION

We welcome your comments or questions about this Policy. Please use the “Contact us”
link of the Altura Platform or contact us in writing at:

Altura Gaming Co.

[email protected]