This Policy describes what kind of Personal Data does the Company collect about natural persons, how does
it collect it, use it, share it with third parties, secure it, process it etc.

In this Policy, and reference to “Personal Data” is to any information relating to an identified
or identifiable natural person; an identifiable natural person is one who can be identified, directly
or in combination with additional information that We have or that We have access to.

In this policy, wherever We refer to the “processing” of Personal Data, We refer to any operation
or set of operations which is performed on Personal Data, including the collection, recording, organisation,
structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

The Company:

The Company is the data controller in respect of the Personal Data about you.

The data protection officer of the Company and the means to communicate with the data protection officer
are:

Data Protection Officer, Progressplay Limited

E-mail:
[email protected]

We collect Personal Data about you whenever you use Our products and services, use the Website, Our service
channels and/or contact Us. In some instances, you will actively provide Us with the Personal Data, and
in other instances We will collect the Personal Data about you from examining and analyzing your use
of Our products and services and/or Our service channels.

You are not obligated to provide Us with any Personal Data about you. However, in some instances, not providing
such Personal Data will prevent Us from providing you with the products or services you request Us to
provide you. Please see below a detailed description of such instances:

A legal obligation of the Company: there are certain legal obligations that require the Company to
collect certain Personal Data as a precondition to providing products and services. In these instances,
while you are not obligated to provide the Personal Data about you, if you will not provide the Company
with such Personal Data, We will not be able to provide you with such products and services.

By way of example, We are required to collect your physical address and country of residence under our regulatory
requirements as holders of online gambling licenses. While you are not obligated to provide Us with such
information, if you will not provide it to Us, We will not be able to register you as a customer and
provide you with Our products and services.

A contractual obligation of the Company: in some instances, the Company is contractually obligated
to provide Personal Data about you. In these instances, while you are not obligated to provide the Personal
Data about you, if you will not provide the Company with such Personal Data, We will not be able to provide
you with the products and services to which the contractual obligation applies.

By way of example, if you do not provide Us with your credit card details, We will not be able to execute
your withdrawal request via such credit card.

Providing Personal Data for the purpose of contracting with you: in some instances, providing Personal
Data about you is a precondition to executing a contract between yourself and the Company. In these instances,
while you are not obligated to provide the Personal Data about you, if you will not provide the Company
with such Personal Data, We will not be able to contract with you and therefore will not be able to provide
you with Our products and services

By way of example, in order to provide you with certain operational messages, relating to the products and
services We provide, We will require to receive your email address.

Personal Data We collect upon registration: email address, first name, last name, gender, date of
birth, physical address, city of residence, country of residence, zip code, phone number, mobile phone
number, currency of account, language of account, publicly available data from the world wide web and
social networks.

Personal Data We collect upon each logging in into your account: IP address, device info, operating
system info, browser info, screen resolution, flash version, current and previous webpages browsed, date
and time of login, location data.  

Personal Data We collect during your use of Our products and services: your deposits, wagers, bonuses,
game session (including date, time and duration), winnings and losses.

Personal Data We collect via Our support: passport / ID / driving license number and photo, utility
bill.

Personal Data We collect upon receiving a deposit of funds and upon a withdrawal request: bank account
details, e-wallet details, credit card details and photo, source of funds details, phone bill, bank statement.

Personal Data We receive from you: any Personal Data you provide to Us on your own free will when
contacting Us, including via customer support, chat, social networks or in any other manner, including
complaints, requests and comments. Our customer support representatives may record and/or document in
writing your calls.

The Company processes your Personal Data for one or more of the purposes outlined in this section and according
to the appropriate legal basis.

The Company shall not process Personal Data about you unless there is a legal basis for such processing.
The legal bases according to which the Company may process Personal Data about you are as follows:

1. Your consent that the Company will process Personal Data about you for one or more specific purposes.
   By way of example, for the purpose of sending you marketing materials.

   Where the legal basis for the processing of the Personal Data about you is consent, you may at any
   time to withdraw your consent for the purposes for which you provided your consent by sending
   a notice free of charge to the following email address
   [email protected], or by changing your settings in your account.

   Where you withdraw your consent for the processing of Personal Data about you, We might not be able
   to provide you with some or all of the products and services you requested or in the form intended
   to be provided to you, and you will have no claim in respect of that.

2. Processing is necessary for the performance of a contract to which you are party or in order to take
   steps at your request prior to entering into a contract. By way of example, for registering
   you as an account holder, or for allowing you to withdraw funds from your account.
3. Processing is necessary for compliance with a legal obligation to which the Company is subject.
   By way of example, on account of Our licensing obligations as holders of online gambling licenses.
4. Processing is necessary for the purposes of the legitimate interests pursued by the Company or by
   a third party. By way of example, for the purpose of improving our products and services,
   or for the exercise or defense of legal claims.

Whenever the processing of Personal Data about you is necessary for the purpose of the legitimate interests
pursued by the Company or by a third party, the processing is conditional upon such interests not overridden
by your interests or fundamental rights and freedoms which require protection of Personal Data about
you. At any time, you may approach Us by sending a notice to the following email address
[email protected] in order to receive information concerning the review performed
by Us in order to reach the conclusion that We may process the Personal Data about you on account of
such processing being necessary for the purposes of the legitimate interests pursued by the Company or
by a third party.

The following list outlines the purposes for which We may process Personal Data about you and the legal basis
for any such processing:

Where the processing of Personal Data about you is necessary for the purpose of the legitimate interests
pursued by the Company or by a third party, you have the right to object to such processing for this
purpose by sending a notice to the following email address
[email protected], unless We demonstrate compelling legitimate grounds for the
processing which override your interests, rights and freedoms or for the establishment, exercise or defense
of legal claims.

The Company provides its customers with offers that are tailored for them specifically, in order to enhance
and improve your user experience and the use of Our products and services, and in order to offer you
with additional and new offers, products and services, including products and services of third parties.
This is done following the processing of Personal Data about you, in order to adjust the materials presented
to you, on the basis of their preferences, behavior, characteristics and interests. For this purpose,
We use Personal Data automated analysis techniques that provide Us with analysis and conclusions concerning
you in various aspects, including profiling.

By way of example, such analysis and conclusions may be used by Us in order to offer you products and services
which We think may be of more interest to you; for instance, on the basis of your playing patterns, your
address and age, the time and day of the week in which you prefer to use Our products and services etc.

Similar analysis and conclusions are used to the extent that you agreed to receive marketing materials from
Us, as such materials are tailored to offer you products and services which We think may be of more interest
to you.

Where Personal Data about you is processed for direct marketing purposes, you shall have the right to object
at any time to such processing for this purpose, including profiling to the extent that it is related
to such direct marketing, by sending a notice to the following email address
[email protected], in which case We shall cease to process Personal Data about
you for such direct marketing purposes.

In addition, you may withdraw your consent from receiving marketing materials at any time, by sending an
email free of charge with the title “unsubscribe” to the following email address:
[email protected]

The Company shares Personal Data with companies within the group of companies of which the Company is a part,
for the purpose of supporting the activities of the Company and the offering of the Company’s products
and services.

The Company may also share Personal Data about you with third parties that provide Us with the following
services:

1. KYC and AML services, aimed to ensure that We comply with all of Our legal, regulatory and licensing
   obligations and requirements.
2. Payment services, such as payment service providers, payment processors and banks.
3. Services in connection with responsible gambling matters; e.g., where We wish to ensure that the scope
   of wagering of a person is compatible with his wealth.
4. Storage and hosting providers, including cloud computing services.
5.  Fraud prevention and chargeback investigation.
6. IP address information.
7. Analysis of user experience.
8. Support.
9. Marketing (including our white label partners and their contractors).
10. Dispatch of materials, including marketing materials, via various means of communications, such as emails,
    SMS, regular (snail) mail, push notifications and other electronic messages.
11. CRM data management.
12. Call enters.
13. Game providers.
14. Digital signing.
15. Accounting and legal services.
16. Research, analytical, technical and diagnostic services.

The Company may share Personal Data about you with governmental, local, official, regulatory, licensing and
gambling authorities, as well as where such disclosure is required to protect Our and third parties’
interests, rights and assets, including initiation or exercise or defense of legal claims.

In addition, We may disclose Personal Data about you to potential purchasers or investors of, or lenders
to, the Company and/or any company within the group of companies of which the Company is a part, or in
the event of any similar transaction (including the sale of assets of the Company and/or of any company
within the group of companies of which the Company is a part), and/or in connection with any merger,
reorganization, consolidation or bankruptcy of the Company and/or any company within the group of companies
of which the Company is a part.

You are entitled to the following rights in respect of the Personal Data about you. The exercise of such
rights will be via sending an email requesting to exercise your right to the following email address:
[email protected]

Right of access

You have the right to receive from the Company confirmation as to whether or not Personal Data about you
is being processed, and, where that is the case, access to the Personal Data and the following information:
(1) the purposes of the processing; (2) the categories of Personal Data concerned; (3) the recipients
or categories of recipient to whom the Personal Data have been or will be disclosed, in particular recipients
in third countries outside the European Economic Area (EEA) or international organisations; (4) where
possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria
used to determine that period; (5) the existence of the right to request from the Company rectification
or erasure of Personal Data or restriction of processing of Personal Data about you or to object to such
processing; (6) the right to lodge a complaint with a supervisory authority; (7) where the Personal Data
is not collected from you, any available information as to its source; (8) the existence of profiling;
and (9) where personal data is transferred to a third country outside the EEA or to an international
organisation, the appropriate safeguards relating to the transfer.

The Company shall provide a copy of the Personal Data undergoing processing and may charge a reasonable fee
for any further copies requested by you where you make the request by electronic means, and unless otherwise
requested by you, the information shall be provided in a commonly used electronic form.

The right to obtain a copy of the Personal Data shall not adversely affect the rights and freedoms of others,
and therefore if the request will harm the rights and freedoms of others, the Company may not fulfill
your request or do so in a limited manner.

Right to rectification

You have the right to obtain from the Company the rectification of inaccurate Personal Data about you. Taking
into account the purposes of the processing, you have the right to have incomplete Personal Data completed,
including by means of providing a supplementary statement.

Right to erasure

You have the right to obtain from the Company the erasure of Personal Data about you where one of the following
grounds applies: (a) the Personal Data is no longer necessary in relation to the purpose for which it
was collected or otherwise processed; (b) you withdraw your consent on which the processing is based
and there is no other legal ground for the processing; (c) you object at any time, on grounds relating
to your particular situation, to processing of Personal Data about you which is based on the legitimate
interests pursued by Us or by a third party, and there are no overriding legitimate grounds for the processing;
(d) you object to the processing of Personal Data about you for direct marketing purposes; (e) the Personal
Data has been unlawfully processed; (f) the Personal Data about you has to be erased for compliance with
a legal obligation in European Union or Member State law to which the Company is subject.

This right is not applicable to the extent that the processing is necessary: (a) for compliance with a legal
obligation which requires processing by European Union or Member State law to which the Company is subject;
or (b) for the establishment, exercise or defense of legal claims.

Right of restriction of processing

You have the right to obtain from the Company restriction of processing of Personal Data about you where
one of the following applies: (a) the accuracy of the Personal Data is contested by you, for a period
enabling the Company to verify the accuracy of the Personal Data about you; (b) the processing is unlawful
and you oppose the erasure of the Personal Data about you and request the restriction of its use instead;
(c) the Company no longer needs the Personal Data about you for the purposes of the processing, but it
is required by you for the establishment, exercise or defense of legal claims; (d) where the processing
of Personal Data about you is necessary for the purpose of the legitimate interests pursued by the Company
or by a third party, unless We demonstrate compelling legitimate grounds for the processing which override
your interests, rights and freedoms or for the establishment, exercise or defense of legal claims; (e)
where Personal Data about you is processed for direct marketing purposes, including profiling the extent
that it is related to such direct marketing.

Where processing of Personal Data about you has been restricted following your request, such Personal Data
shall, with the exception of storage, only be processed with your consent or for the establishment, exercise
or defense of legal claims or for the protection of the rights of another natural or legal person or
for reasons of important public interest of the European Union or of a Member State.

Right to data portability

You have the right to receive the Personal Data about you, which you have provided to the Company, in a structured,
commonly used and machine-readable format and have the right to transmit such Personal Data to another
controller, where: (a) the processing is based on your consent or on a contract to which you are a party;
and (b) the processing is carried out by automated means.

In exercising your right to data portability, you have the right to have the Personal Data about you transmitted
directly from the Company to another controller, where technically feasible. The exercise of your right
to data portability is without prejudice to your and the Company’s rights under your right to erasure.
In addition, the right to data portability shall not adversely affect the rights and freedoms of others.

Right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing
of Personal Data about you which is based on the legitimate interests pursued by the Company or by a
third party, including profiling based on such legitimate interests. We shall no longer process the Personal
Data about you unless We demonstrate compelling legitimate grounds for the processing which override
your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

You have the right to object at any time to the processing of Personal Data about you for direct marketing
purposes, which includes profiling to the extent that it is related to such direct marketing.

Right to withdraw consent

You may withdraw your consent provided to Us for the purpose of processing Personal Data about you at any
time, without affecting the lawfulness of processing based on consent before its withdrawal.

Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a supervisory authority which is established by a Member State
in order to protect the fundamental rights and freedoms of natural persons in relation to processing
of personal data within the European Union.

Your rights in respect of Personal Data about you as outlined in this section 11 may be restricted by European
Union or Member State law to which the Company is subject to.

We shall provide you with the information requested according to your rights outlined in this section 11
without undue delay and in any event within one month of receipt of the request. That period may be extended
by two further months where necessary, taking into account the complexity and number of the requests.
We shall inform you of any such extension within one month of receipt of the request, together with the
reasons for the delay.

The information requested according to your rights outlined in this section 11 shall be provided free of
charge, unless stated otherwise in this section 11. Where requests are manifestly unfounded or excessive,
in particular because of their repetitive character, We may either: (a) charge a reasonable fee taking
into account the administrative costs of providing the information or communication or taking the action
requested; or (b) refuse to act on the request.

The Company may require you to provide additional information necessary to confirm your identity in order
to fulfill your request according to your rights outlined in this section 11, where We have reasonable
doubts concerning the identity of the natural person making the request.

General

When you visit or access the Website and/or use Our products and services, a cookie file (which is a small
text file) is installed on the device via which you visit or access the Website and/or use Our products
and services. The cookies allow Us to collect information about you and your behavior, in order to improve
your user experience, to remember your preferences and settings, to customize and offer you with products
and services that may interest you. Cookies are also used collect statistics about your usage of Our
products and services and perform analytics.

Some of the cookies We use are session cookies, which are downloaded temporarily to your device and last
until you close your web browser, while others are persistent cookies which last on your device after
you cease browsing the Website and are used to help the Website remember you as a returning visitor when
you return to the Website.

Types of cookies

The cookies We use have classified according to their functionality, as follows:

Blocking and removal of cookies

You can change your browser settings in order to block and delete some or all cookies. Please see below links
to instructions as to how to do this in respect of some of the most popular web browsers:

• Firefox
• Internet Explorer
• Google Chrome
• Safari

Please note, however, that if you do so, some or all of the Website’s features and functionalities
might not perform as intended.

The Company shall retain Personal Data about you for as long as is required to fulfill the purposes of the
processing of the Personal Data as outlined in this Policy, or for a longer period as required according
to the legislation, regulation, policies and orders that apply to Us.

In general, We will hold Personal Data about you for a minimum period of five years after the termination
of your account with Us.

In order to ensure that Personal Data about you is not retained for longer than is required, We periodically
review Personal Data retained by Us in order to examine whether any Personal Data can be erased. 

Personal Data about you may be transferred to a third country (i.e., jurisdictions outside the EU Member
States, Iceland, Norway and Liechtenstein) or to international organisations. In such circumstances,
the Company shall take appropriate safeguards aimed to ensure the protection of Personal Data about you
and provide that enforceable data subject rights and effective legal remedies for data subjects are available.

These safeguards and protection will be available if any of the following are met:

1. The transfer is to a third country or an international organization which the EU Commission decided that
   they provide an adequate level of protection to the Personal Data that is transferred to them pursuant
   to Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27
   April 2016 (”
   GDPR“);
2. The transfer is according to legally binding and enforceable instrument between public authorities or
   bodies pursuant to Article 46(2)(a) of the GDPR; or
3. The transfer is in accordance with standard data protection clauses adopted by the EU Commission pursuant
   to Article 46(2)(c) of the GDPR; the clauses adopted by the EU Commission can be viewed at
   
   https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
   

You may request the Company to be provided with details concerning the safeguards employed by it to protect
the Personal Data about you which is transferred to a third country or an international organization,
by sending an email to the following address:

We implement appropriate technical and organisational measures to ensure an appropriate level of security
to Personal Data taking into account the risks that are presented by processing, in particular from accidental
or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Data transmitted,
stored or otherwise processed.

We may be required, due to legal or other obligations outside Our control, to transfer Personal Data about
you to third parties, such as public authorities. In such circumstances, We have limited control over
the level of protection provided to the Personal Data about you by such third parties.

Any transfer of Personal Data via the internet cannot be fully secured. Therefore, the Company cannot ensure
the protection of Personal Data about you when transferred via the internet to the Website operated by
the Company.

The Website may provide links to websites and/or applications of third parties. The Company does not control
such websites and applications, nor the collection and/or processing of Personal Data about you by such
websites and applications, and We are not responsible for such websites and applications, nor to their
privacy and data protection policies and activities. This Policy does not apply to any actions taken
via such websites and/or applications.

Wherever you access such third parties’ websites and/or applications, We recommend that you carefully review
their privacy policies prior to using such websites and/or applications and prior to disclosing any Personal
Data by you.

We may amend, from time to time, the terms of this Policy. Whenever We amend this Policy, We will notify
such amendments by publishing the updated Policy on the Website. In addition, when We make significant
amendments of this Policy, We will strive to inform you about such amendments via means of communication
which We believe are reasonably appropriate to inform you of such amendments and by publishing a notice
about such amendments on the Website. Unless stated otherwise, all amendments will enter into force upon
publishing the updated Policy on the Website.