Responsible Social Gameplay policy of BroadcasterDawn

BroadcasterDawn is committed to the protection of our players and promoting responsible socialgameplay as a policy of customer care and social responsibility. We believe it is our shared responsibility with you, our customers, to ensure that you enjoy yourexperience on our Platform while remaining aware of the potential risks that can be associated with online gameplay if you don’t remain in control. We encourage you to use the responsible social gameplay tools described below available at your disposal. To ensure that you enjoy fun and affordable play, we fully support responsible social gameplayand have put measures in place to assist customers who wish to control their play. We reservethe right to activate these measures unilaterally if, in our sole discretion, we consider themnecessary.

1. INTRODUCTION

1. This Responsible Social Gameplay Policy (RSG Policy) describes the control tools,information and resources available to registered players on BroadcasterDawn.

1.2. This RSG Policy forms part of the BroadcasterDawn Terms of Service. Terms which aredefined in the Terms of Service have the same meaning in this RSG Policy.

1.3. We may update the RSG Policy at any time. Any amendments will be published on thePlatform and such changes will be binding and effective immediately.

1.4. Whenever we amend this RSG Policy in a way that would limit your current rights or which may be detrimental, we will notify you upon your next visit to the Platform and youwill be required to re -confirm your acceptance prior to playing any Games. If you do notagree to the amended RSG Policy, you must stop using the Platform.

2. BroadcasterDawn RSG Program

2.1. The BroadcasterDawn Responsible Social Gameplay Program (RSG Program) is centered around our guiding principles of providing our customers with control tools,information and help resources needed to:

(a)Make an informed decision in gameplay

(b)Prevent problem gameplay from occurring on our site.

2.2. The RSG Program is designed to support the needs of individuals at any stage of the customer journey, from registration to redemption, and any level of gameplay. To do this,the RSG Program offers a range of player education, control tools and resources for professional help when needed.

2.3. BroadcasterDawn also understands that it is a shared responsibility to achieve a fun and affordable gameplay environment and that it is ultimately an individual’s choice to play. We do not provide counseling services nor do we police customer behavior. Instead, we focus on providing control tools and informing, educating and supporting informed decisions.

2.4. BroadcasterDawn has well-trained staff available to assist you in relation to your gameplay. Our staff are encouraged and empowered to provide information and offer control tools proactively.

3. RSG ACCESS CONTROL TOOLS

The access control tools described below are available if your gameplay may have become, or is at risk of becoming, problematic (see “What is Problem Gameplay” in section7.4).

3.1. Taking a Break – Accessible through the “Contact” form on the Platform under“Responsible Social Gameplay options”.Allows you to take a short break from gameplay. During this time you will not be able to access your account.

(a) Available options are 1 day, 3 days, 7 days, 14 days or 30 days.

(b) It will not be possible to reactivate your account until the chosen period ends.

3.2. Self-Exclusion – Accessible through the “Contact” form on the Platform under “Responsible Social Gameplay options”.

A self-exclusion allows you to suspend your account for a longer time period. During thisperiod you will not be able to access your account.

(a) Available time period options are 6 months, 1 year, 3 years, 5 years andIndefinite. If your account has been verified to our satisfaction, we will usereasonable endeavors to arrange for any Sweeps Coins remaining in youraccount which satisfy our playthrough requirements and meet our minimumredemption threshold to be redeemed.

(b) You will be unsubscribed from receiving any marketing communications.

(c) It will not be possible to reactivate your account until the chosen time period ends.

(d) Where a defined self-exclusion is in effect, your account will automaticallyreactivate once the chosen time period has lapsed.

(e) Where an indefinite self-exclusion is in effect, a minimum of 6 months must passbefore the account can be reactivated.

(f) Where an indefinite self-exclusion is in effect, a 7-day cooling period will applybefore the account is reactivated.

3.3.Permanent Closure – Please contact customer support

(a) You may choose to permanently close your account. If you wish to do so, send a written email to Customer Support via Contact Us requesting a “Permanent Account Closure” and state the reason for the closure.

Please note that, unlike an indefinite self-exclusion, a permanent closure is irreversible and cannot be reactivated under any circumstances.

(b) You will be required to provide a “confirmation of understanding” to permanently close your account.

4. SELF-ASSESSMENT

If your gameplay may have had, or is at risk of having, a negative impact on your mentalhealth, finances or relationships with friends or family, we encourage you to get in touch with the following help and support organizations:

5. SUPPORT ORGANISATIONS

If your gameplay may have had, or is at risk of having, a negative impact on your mentalhealth, finances or relationships with friends or family, we encourage you to get in touch with the following help and support organizations:

(a) Counseling

Gaming Addicts Anonymous (GAA) is a fellowship of people who support each other in recovering from the problems resulting from excessive game playing.

(b)Credit Counseling

(i) Financial Counseling Association of America (FCAA) is a professionalassociation of financial counseling agencies that assist consumers withfinancial counseling services of all kinds, as well as debt managementplans for the repayment of unsecured debts.

(ii)
National Foundation for Credit Counseling (NFCC) is one of the oldestnetworks of non-profit financial counseling agencies. The NFCC helpspeople to defeat their debt and look forward with confidence.

(c) Please note that these organizations are independent support services and areNOT in any way affiliated with BroadcasterDawn. They do NOT provide customersupport or dispute resolution services. Should you wish to discuss any matter or complaint related to your account, you can do so by contacting us using this Contact Us form.

6. EDUCATION INFORMATION ON RESPONSIBLE SOCIAL GAMEPLAY

6.1. Principles of Gameplay

(a) Randomness: Remember that game round outcomes are completely random.Results cannot be predicted and are independent of past or future outcomes.

(b) Return to Player (RTP): This is the average return on the winnings and prizesover the lifetime of a slot-type game. I.e., if a slot type has an 8% advantage, then the average RTP will be 92%.

(c) Advantage: All casino-type games are designed with a slight advantage that favors the operator.
6.2.Common Misconceptions

(a) “I’m due for a win” – You cannot predict when you’re going to win. All out comes are random.

(b) “I always win with my lucky charm and pre-game ritual” – Although they might be fun, charms and
rituals don’t affect your chances of winning. All outcomes are random.

(c) “The longer I play, the more chance I’ll win” – Time spent has no effect on yourchances of winning. All outcomes are random.

(d) “These games have been rigged” – The Random Number Generator (RNG) used in all BroadcasterDawn games is the same code base as the RNG independently certified by iTechLabs and Gaming Associates, who confirmed that the RNG uses a well-known algorithm to generate random numbers. The numbers generated by the RNG have passed Marsaglia’s “diehard” tests for statistical randomness.iTech Labs and Gaming Associates have found that number sequences areunpredictable, non-repeatable, and uniformly distributed.

6.3. Tips for Safe Gameplay

(a) Avoid gameplay while upset or emotional.

(b) Take frequent breaks during your gameplay sessions.

(c) Avoid gameplay while intoxicated.

(d) Avoid canceling redemptions.

(e) Remember that gameplay is only a form of entertainment, it should not be seenas a source of income or an escape from reality.

(f) Purchase only with money that you can afford to spend.

(g) Set a budget and don’t go over it.

(h) Set a time limit before playing.

(i) Understand how games work before playing and remember that the results arerandom.

(j) Never let gameplay affect your employment, relationships, health or commitments.

6.4.What is Problem Gameplay?

(a) Financial

(i) Cannot pay bills

(ii) Borrowing money to maintain life expenses

(iii) Eviction or loss of home

(iv) Repossession of car and valuables.

(b) Family

(i) Unhappy home environment

(ii) Missing family events and gatherings

(iii) Disconnect and disassociation of family members.

(c) Employment

(i) Missing work

(ii) Reduction in productivity and competence

(iii) Loss of employment.

(d) Health

(i) Anxiety

(ii) Depression

(iii) Isolation

(iv) Increases stress.

(e) Know the Signs

(i) Purchasing beyond one’s means

(ii) Not being able to pay bills due to excess spending

(iii) Staying home from work to play

(iv) Feeling frustrated on days when not playing

(v) A constant need to increase the level of play to reach the same levels of fulfillment and excitement

(vi) Playing in order to escape from the stress of life

(vii) Lying about the amount of money or time that is spent

(viii) Hiding play behavior from significant others

(ix) Putting gameplay above one’s family, friends, or other interests

(x) Lying, borrowing, stealing, or committing fraud to get money to play

(xi) Depressive or even suicidal feelings during or after playing.

7. PLAYER PROTECTION POLICY

7.1 Protection of the vulnerable

(a) Make sure that the decision to play on our Platform is your own personal choiceand responsibility.

(b) We do not recommend playing on our Platform if you:

(i) are being treated or are in recovery for an addiction/dependency

(ii) are under the influence of alcohol or any other substance

(iii)are currently experiencing financial difficulty or a traumatic life event

(iv) do not understand how to play the Games

(v) have any mental health concerns, cognitive impairment or brain injury.

7.2.Protection of Minors

(a) BroadcasterDawn has identity checks in place to mitigate and prevent the risk of underage gameplay on our Platform.

(b) If you share your mobile phone, tablet, laptop or computer with friends or familywho are under the legal age to participate in online social gameplay, werecommend that you restrict their access to our Platform by using one of thebelow services:

(i) Netnanny.com – filtering software that protects children from inappropriateweb content.

(ii) Cybersitter.com – filtering software that allows parents to add their ownsites to block.

Company Information:

BroadcasterDawn(the “Site”) – This privacy policy applies to all of BroadcasterDawn services and products. You should be aware that BroadcasterDawn cannot be held responsible for the privacy policy of other sites and sources.
BroadcasterDawn will act as the data controller in the framework of this Privacy Policy. By clicking “Agree & Continue”, you provide your consent with the specific aspects of this Privacy Policy and you affirm that you are of legal age to agree to the terms of this Privacy Policy.
Whenever important changes are made to this Privacy Policy, we will notify you. BroadcasterDawn respects the privacy of all users of its Site and shall ensure the personal information you provide is treated confidentially.
We are aware of the trust you place in us. We see it as our responsibility to protect your privacy. On this page, we will let you know what information we collect when you use our Site, why we collect it and how we improve your user experience. Thus, you will understand exactly how we work.

I. WHICH DATA DO WE COLLECT?

1. Data we receive from you
Contact form: When you fill in the contact form provided on our Site or send us an e-mail, we will optionally process the following types of personal data on the basis of consent:
• First name
• Name
• E-mail
• Other information that you provide

Account registration: If you register an account with us you give explicit consent to collect a password, email address, phone number, user agent, and IP address. We do not store this data ourselves but work with Google Firebase authentication services to do so. The data is used to enable end-user authentication, and facilitate end-user account management. It also uses user-agent strings and IP addresses to provide added security and prevent abuse during sign-up and authentication. We use Firebase as described in “How Google Uses Information From Sites Or Apps That Use Our Services”.

IP addresses are logged for a few weeks. Other authentication information is retained until you initiate deletion of the associated user, after which data is removed from live and backup systems within 180 days. You can delete your account via Account Settings.

2. Data we receive automatically

We can collect some personal data through the use of cookies: see Section V of this Privacy Policy.

Some other (personal) data may be collected without the use of cookies. Said data can only be read and used during your visit to our Site:

• Your IP-address (used e.g. for preventing double voting and location based advertising);do, por exemplo, para prevenir votação dupla e publicidade baseada em localização);
• Your browser type and revision;
• The last visited internet page;
• (mobile) device ID’s;
• cookie data;
• user level data (i.e. whether a user viewed or clicked on an advertisement);

3. Data we receive from third parties

When we receive Personal Information from third parties, we will inform you personally.

II. WHY DO WE COLLECT THESE DATA? BASED ON WHICH LEGAL GROUND?

Your personal data will be used to enable us to optimise the services we render and the content we provide on the Site. In certain cases when we are under a legal requirement to process personal data, like age limits, we will process these personal data.
We may also use your personal data for direct marketing purposes, such as updates on new or existing games and newsletters.
We may opt to use your personal data for statistical purposes and to improve our services and product. These processing activities are thus based on a justified legitimate interest of BroadcasterDawn.
We do not carry out any automated individual decision-making, including profiling, within the meaning of article 22 of the General Data Protection Regulation (EU 2016/679) which would require your explicit consent.
Advertisers on our website might use information gathered by the use cookies and/or web beacons for the purpose of online behavioral advertising and/or multisite advertising. Further information as regards the use of cookies and web beacons is set out in Section V below.
Additionally, we may share information that we collect from you, such as your email (in hashed form), IP address or information about your browser or operating system, with our identity partners/service providers. These partners return an online identification code that we may store in our first-party cookie for our use in advertising and it may be shared with advertising companies to enable interest-based and targeted advertising. To opt out of this use, please click here.
BroadcasterDawn is not responsible for any personal data collected via any third party software or methods present on the Site and to which said third parties’ general terms and conditions may apply.
You are advised not to use your real name or share any other personal information in any of the games provided on our Site including, without limitation, when engaging in multi-player.
We have the right to share your data with all Google CPS Vendors so that Google DV360 may return GDPR compliant bids for ad delivery.

III. DATA RETENTION PERIODS

Your personal data will only be processed for as long as this is necessary for the purposes mentioned above. Unless there is a justified reason to retain the personal data, for example within the framework of customer relation management, your personal data will be deleted one month after you failed to visit our site during a consecutive period of [2] years.

IV. YOUR RIGHTS

You can get access to your personal data and rectify or erase them, free of charge. You also have the right to restrict the processing of your personal data.
If you do not wish to receive newsletters or information about our products or services, you can at any moment and without any need for justification, object to the processing of your personal data for these purposes (“unsubscribe”). You can do this by sending us an e-mail or by contacting as at the address mentioned below. You can also do this by clicking on the unsubscribe link in our advertising e-mails.
Moreover, you have the right to data portability for the personal data you have provided to BroadcasterDawn if any and to the extent that BroadcasterDawn has retained your personal data. If you want more information on your rights, you can always contact us or take a look at the website of the Belgian Data Protection Authority:
https://www.dataprotectionauthority.be/.
To exercise these rights, we ask you to send a clear request, to the address mentioned below, that states clearly what it is you want to know, rectify or erase. This request needs to be signed and dated and contain a copy of the front side of your identity card.
You should specifically motivate your request if you want to rectify or erase personal data or restrict the processing thereof. Once these conditions are fulfilled, BroadcasterDawn will execute your request as soon as possible and send you a message on this matter.

V. COOKIES

**What are cookies?**

Cookies are small files that are saved on your computer when you visit web pages. They contain information linked to a web browser and the specific website. They are saved in a specific folder on your hard drive. If you return to a specific website, this page can recognize the visitor by means of the cookie and further elaborate the history. A web beacon is an (often transparent) graphic image, usually no larger than 1 pixel, that is placed on a website and that is used to monitor the behavior of the user visiting the website.
Cookies are used to increase visitor-friendliness: by identifying visitors with a cookie, they do not always have to enter the same data such as login information or screen settings every time you visit the website.

Which kind of cookies exist?

Often a distinction is made between two large groups of cookies:

• First party cookies: these cookies are created by a website to have the web page function better. They regulate the technical part of a site, such as language choice or remembering the products in the shopping basket in an online store. The visited website creates and places first party cookies.
Third party cookies: these cookies are created and placed on your computer by another (third) party than the website you visit. They remember the behavior of a surfer. Examples are social media such as Facebook or Twitter, but Google Analytics as well. This is the system used most to measure website visits.
Cookies required for the correct functioning of the Site do not require permission. All other cookies do.

Which cookies do we use?

We will only use first party cookies to help improve your user experience on the Site. We would do this by recording specific information about the user such as the language chosen, the pages visited and the duration of the visits.
We may offer games from third-party game distributors on our portal. By playing a third-party game, your Personal Data may be processed by the third-party game distributor (directly or through the use of cookies or similar technology). Please note that if you choose to play a third-party game, you are playing that game in the environment of that game’s third-party developer, over which we have no control. We, therefore, recommend that you read the privacy statement of that game distributor before playing the game.
Game Distribution: Privacy Policy
Via our Consent Management Platform (CMP), which you can access at the right top corner of this page via the Show Preferences button, you can configure your cookie preferences.
Third parties might use information gathered by cookies and/or web beacons for the purpose of online behavioral advertising and/or multisite advertising. The types of information that is gathered by third party cookies and/or web beacons as well as the purpose(s) for which this information is used, are set out in the privacy policy of said third parties which BroadcasterDawn encourages you to review. BroadcasterDawn declines all and any liability for any third party cookies or web beacons deployed by third parties for whatever purpose.
Google Analytics is a free service by Google to collect statistics of websites and to represent them in detail. The website administrator thus has a clear view on visitor flows, traffic flows and page displays. This way it is possible to adapt parts of a website or complete websites to the behavior and interests of the visitors.

How to manage cookies?

You can do so by adapting your browser settings. Modern browsers allow you to choose to block cookies or to accept only cookies from specific websites. Contact us if you need any help in doing so.

VI. SECURITY MEASURES

BroadcasterDawn has taken all reasonable and appropriate technical and organizational measures to ensure that your Personal Information is processed securely.
If you have any questions on these security measures, feel free to contact us at the address mentioned below.
Within BroadcasterDawn , personal data is only available to people who need to have access to it in relation to their job.
At no moment in time will we directly sell or rent out your personal data to third parties. Occasionally we may use an external processor. If we do this, we will always ensure that your information is handled confidentially and in a safe manner.
We also always draw up a contract with these processors. This way the processor will never be allowed to use your data on its own initiative and your data has to be erased as soon as the processor has finished the assignment

VII. CONTACT INFORMATION OF DATA CONTROLLER

For all your questions or complaints regarding this Privacy Policy, you should contact us at the following e-mail address: [email protected] or through our contact form.

Afterwards, you can contact your Data Protection Authority to assist you or to file a complaint.