Privacy and Cookies Policy

This Privacy Policy was last updated on 20.03.2024. We are STATBET LLC, a company duly incorporated and registered under the laws of Ukraine, with the registered office at Ukraine, 01014, Kyiv, Boichuka St. 41-Б, office 2018 (collectively, "Statbet", "we", "us", "our"), which operates website https://top2u.io/ ("Website"). This privacy and cookies policy ("Privacy Policy") is designed to inform you how your Personal Data (as defined in this Privacy Policy) is collected, processed and used. You may provide your Personal Data while you use our Website. This Privacy Policy also describes your choices regarding use, access and correction of your Personal Data. If you do not agree with the data practices described in this Privacy Policy, you must not access and/or use the Website. For European Union (“EU”) users, this Privacy Policy is subject to the provisions of the General Data Protection Regulation ("GDPR"). Under the GDPR, Top2u is a data “Controller”, you are a “Data Subject” with certain protected privacy rights concerning your Personal Data, and Top2u may use “Processors” to the extent necessary to provide you with the access to Website and related services described herein. If you wish to comment or ask questions regarding this Privacy Policy, please reach us out using email [contact email]. This Privacy Policy does not apply to third party websites that you may be able to access via links on the Website. Top2u is not liable for any cases of Personal Data misuse, which occurred due to your use of third party websites. The use of the Website is only permitted provided that you have granted a consent for processing of your Personal Data. You must refrain from accessing and/or using the Website if you do not give consent for processing of your Personal Data. The following explains our views and practices regarding your Personal Data.

1. Definitions "Personal Data" means information that you voluntarily submit to us which may identify you as an individual, such as email address, username, ID assigned by our system, first and last name, phone number and address. Personal Data may also include Navigational Information. "Navigational Information" refers to information about your device and your visits to our Website, such as your IP address, geographical location, browser type, length of visit and pages viewed. Which Personal Data we collect? We may collect the following data about you: • Data you may give us in the process of creation of an account and use of the Website, you provide us your personally identifiable information, in particular, first name, last name, username, phone number, email address, age and date of birth. • Data that you may upload to the Website, including images and profile pictures. • Data you may provide during your participation in surveys on our Website if you chose to do so. • We may process your interaction with the Website and other users, such as likes, tips, comments, your following activities and preferred content. • Data we may collect about you when you use the Website including technical information such as type of device, the Internet Protocol (IP) address used to connect your device to the Internet, any login information, browser type and version, time zone, browser plug-in types and versions, operating system, mobile network information and platform, pages you viewed, Website content you view or interact with, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

2. Purpose and legal basis for processing your Personal Data We, either directly or through our Processors, will, use your Personal Data for the purposes stated below: • To provide you with our services through the Website. This includes: o Providing you with access to the Website and its contents. o Sending necessary communications by e-mail or other means. o Providing user service or support. • As required to conduct our business and pursue our legitimate interests, in particular: o Granting you an access to the Website and its contents. o Improving security of the Website, and identifying and preventing fraud. o Investigating and responding to any comments or complaints that you may send us directly or through social media. o Identifying and fixing any problems encountered by you at the Website. o Analyzing your use of the Website and your preferences in content of our Website. Our Website is designed to provide you with personalized feed, thus we have a legitimate interest in better understanding how our Website is being used and which content you prefer the most. o Using automated systems (including machine learning) to analyze the way you use the Website in order to improve our Website and the user experience (but only where your consent is not required). o Conducting surveys and other market research to collect and analyze information about our users, their interests, the effectiveness of our marketing campaigns, and user satisfaction (but only where your consent is not required). o Using information in connection with legal claims, compliance, regulatory and investigative purposes, including disclosure of information as required by law enforcement authorities or any litigation. • To comply with applicable laws and regulations. We may process your information for the purposes of: o Compliance with legal requirements and law enforcement in case we are required to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. o Responding to requests by government or law enforcement authorities conducting an investigation. o To detect, prevent, or otherwise address fraud, security or technical issues and software piracy.

3. How we use your Personal Data In addition to the uses identified elsewhere in this Privacy Policy, we, either directly or through our Processors, may use your Personal Data to: o to administer your account and provide you with access to the Website (creating and managing your account, providing you with user support services, managing your requests); o improve your user experience by personalizing the Website and its content; o provide anonymized, statistical information about our users to our business partners; o send information to you regarding changes to our Privacy Policy or other legal agreements; or o meet legal, accounting, or reporting requirements imposed on us. We, either directly or through our Processors, also use information collected through our Website for the following purposes: o to improve the Website (which may include the detection, prevention and resolution of security and technical issues); o to respond to user support requests.

4. When you use our Website We employ analytics software to enhance our comprehension of how our Website operates across various devices, utilizing cookies installed on your device to aid in this endeavor. This software collects data including your frequency of Website usage, events within the Website, aggregated usage patterns, performance metrics, and the origin of application downloads.

5. Marketing With your consent, we would like to provide you with information about products, services and opportunities, which may be of interest to you. This information may be conveyed via email or tailored online content and advertisements on our website, social media channels, or in collaboration with our online affiliates. If you opt in by selecting the appropriate checkboxes, you retain the freedom to revise your decision at any point by informing us directly or using the unsubscribe option included in our marketing communications, if applicable.

6. Disclosure of your Personal Data We may share your Personal Data with third parties in accordance with this Privacy Policy, including: • other entities of the Statbet group, i.e. entities under our control or that are under common control with us may have access to your Personal Data, including Processors, but will adhere to this Privacy Policy; • service providers, including Processors (for example, analytics services, software developers, IT support service providers), business partners, suppliers and sub-contractors, for the performance of any services we provide to you, or who provide you with marketing communications; • analytics and search engine providers that assist us in the improvement and optimization of the Website; • government or other law enforcement agencies, in connection with an investigation of unlawful activities or for other legal reasons (includes your location information); • if we sell any business assets or receive loans or investment into our business, we may disclose your Personal Data to the prospective buyer, lender or investor; • to our legal and other professional advisors for the purposes of taking advice; and

7. Where we store your Personal Data Website can be accessed and used worldwide. We may store and hold data collected in accordance with this Privacy Policy on systems located outside the European Economic Area (“EEA”), and may process it outside the EEA, including in instances where users are not based in the EEA, or where Website is accessed by a user who is not a resident of the EEA.

8. Retaining Personal Data Even if you request that we erase your data, we may still need to keep it under some circumstances, or may keep it as anonymous data. We will only retain your Personal Data for as long as necessary to fulfil the purposes for which we collected it, which includes satisfying any legal, accounting, or reporting requirements imposed on us. To determine the appropriate retention period for Personal Data, we consider the amount, nature, the basis of processing, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. If we anonymize your Personal Data so that it can no longer be associated with you, we may use such information without further notice to you. If we are processing Personal Data as part of an agreement and you have not agreed that we may use your data for marketing purposes, we will retain your Personal Data on record for no more than the duration of the agreement and 6 month thereafter.

9. Security All information you provide to us is stored on secure servers. We use technical and organizational measures to safeguard your Personal Data. If you have a user name (email) and a password which enable you to access Website, you are responsible for keeping these access details confidential. Please do not share your user name or password with anyone. Along with anyone with whom we share your Personal Data, we maintain appropriate technical and organizational measures for an appropriate level of security in respect of all Personal Data we process. However, the transmission of information via the internet is not completely secure. While we take reasonable measures to protect your Personal Data, we cannot guarantee the security of data transmitted to the Website, and you acknowledge that any transmission of data is at your own risk. Once we have received your information, we use procedures and security features which are appropriate to the type of Personal Data you have provided to make reasonable commercial efforts to prevent unauthorized access or inadvertent disclosure.

10. Measures used to protect personal information of users For the purposes of maintaining the security of your Personal Data, we recommend you to adhere to the following rules: • log out of our account at the end of the session; • do not share the password to your account with anyone; • change password to your account at least once every 3 months. Notwithstanding the abovementioned, we recommend you not to place your own email addresses, messenger details, phone numbers, accurate addresses, credit card details, national identification data, driver's numbers certificates and other vulnerable information in public sections of Website that are open for abuse and misuse. In case of provision of personal information by you to other users in the process of communication, we are not responsible for any misuse your Personal Data received by such users.

11. Your rights You have the following rights with regard to your Personal Data: • Access. You have the right to access data we hold about you. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it. • Rectification or erasure. You have the right to request that we rectify or delete any Personal Data that we hold about you, unless we have the legal right to retain it, and you may withdraw your consent to our use of your Personal Data. This right does not extend to non-Personal Data. Further, if you request that we erase certain Personal Data or to enable us to provide services to you, you may no longer be able to access the Website. • Restriction. You also have the right to restrict us from processing your Personal Data if the data is inaccurate, the processing is unlawful, or we no longer need your Personal Data for the purposes for which we hold it. • Data portability. If the legal basis that we rely on for processing your Personal Data (as we describe in the section Purpose and legal basis for processing your Personal Data) is either consent, or the provision of services to you, or if your Personal Data is being processed automatically then, to the extent feasible and that it does not adversely affect the rights of others, you have the right to ask us to provide you with the Personal Data that you have provided to us, in a structured, commonly used and machine-readable format. This could include data that we hold that results from observation of your use of the Website. • Object / change of preferences. You have a right to request that we stop processing your Personal Data where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your Personal Data for direct marketing purposes. For example, if you have given your consent to receive updates from us, but have changed your mind, you have the ability to opt out from receiving future marketing communications by clicking the relevant link in any communication you receive, or by contacting us directly. • Unsubscribe From Our Communications. You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, updating your communication preferences, or by sending us an email at [contact email]. • Complaints. If for any reason you are not happy with the way that we have handled your Personal Data, please contact us. If you are still unsatisfied, you may make a complaint to the Office of the Commissioner for Personal Data Protection. Please note that the rights mentioned above do not extend to non-Personal Data. If you would like to exercise any of the rights mentioned above, please send us an email at [contact email].

12. California residents The California Consumer Privacy Act (CCPA) requires us to disclose categories of Personal Data we collect and how we use it, the categories of sources from whom we collect Personal Data, and the third parties with whom we share it, which we have explained above.

We are also required to communicate information about rights California residents have under California law. You may exercise the following rights:

• Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Data we collect, use, or share; (2) purposes for which categories of Personal Data are collected or used by us; (3) categories of sources from which we collect Personal Data; and (4) specific pieces of Personal Data we have collected about you. • Right to Equal Service. We will not discriminate against you if you exercise your privacy rights. • Right to Delete. You may submit a verifiable request to close your account and we will delete Personal Data about you that we have collected.

If you would like to exercise any of these rights, please contact us.

We do not sell the Personal Data of our users.

1. Cookies policy Cookies pixels, and other technologies (collectively, “cookies”) are small files that contain information which is transferred to and from your computer's or mobile device’s hard drive. These technologies help us better understand user behavior, tell us which part of our Website people have visited, and facilitate and measure the effectiveness of advertisements and web searches. By continuing to access and use the Website you accept our cookies policy set forth herein. At the same time you are free to explore the Website without providing any Personal Data, if you have disabled cookies in your internet browser. If you have not disabled cookies, our Website may use cookies to track your use of the Website and collect Navigational Information. We use the following cookies: • Strictly necessary cookies. These are cookies that are required for the operation of the Website. • Functionality cookies. These are used to recognize you when you return to the Website. They enable us to personalize content for you, greet you by name and remember your preferences, for example, your choice of language. • Analytical/performance cookies. These allow us to recognize, count the number of visitors, and see how visitors move around the Website when they are using it. This helps us to improve the way the Website works. • Targeting cookies. These cookies record your visit to the Website, the pages you have visited, Website content you have interacted with and the links you have followed. We will use this information to make the Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

2. Why we use cookies We use cookies to recognize your browser and your device, learn more about Website content you prefer the most and for other purposes. More specifically, these include: • Recognizing you when you sign in to use our Website. This allows us to provide you with product recommendations, display personalized content, and provide other customized feed. • Conducting research and diagnostics to improve Website content. • Preventing fraudulent activity. • Improving security. • Delivering content, including ads, relevant to your preferences on Website and third-party sites (see the “Targeted Ads” section below for how we use cookies in serving interest-based ads and how to disable them). • Cookies allow you to take advantage of some of the Website’s essential features. For instance, if you block or otherwise reject our cookies, you may not be able to use any of our products or services that require you to sign in. Approved third parties may also set cookies when you interact with the Website. Third parties include search engines, providers of measurement and analytics services, social media networks, and advertising companies. Third parties use cookies in the process of delivering content, including ads relevant to your preferences and to measure the effectiveness of their ads.

3. Targeted ads We might utilize cookies in conjunction with a third-party advertising network to present advertisements on our Website or to help in managing and monitoring our advertising on external sites and services. Our advertising network collaborators employ cookies and web beacons to gather data about your interactions on our Website and other platforms, enabling them to deliver personalized advertising tailored to your preferences. If you prefer not to have your information utilized for targeted advertising, you have the option to opt-out by reaching out to us at [contact email].

4. Managing cookies You can manage browser cookies through your browser settings. The 'Help' feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable cookies, and when cookies will expire. If you disable all cookies on your browser, neither we nor third parties will transfer cookies to your browser. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some features and services may not work. For additional, more detailed information about cookies and how they can be managed and deleted, please visit www.allaboutcookies.org.

5. Children and young people’s information Minors are not allowed to access our Website. We do not knowingly collect any information from any minors under the age of 18. If you have concerns about this Website, wish to find out if your child despite the restrictions imposed by our Terms of Use has accessed our services, or want us to remove your child's Personal Data from our servers, please reach us at [contact email].

6. Changes to our Privacy Policy Any changes we make to our Privacy Policy will be posted on this page and when possible, we will also notify you by e-mail. Continued use of the Website will signify that you agree to such changes.

How to contact us Questions, comments and requests regarding our Privacy Policy are welcome and should be addressed to privacy@statbet.com. Please also contact us if you would like to update or amend any Personal Data provided to us, or if you believe our records relating to your Personal Data are incorrect.