Privacy policy
September 2022
Version 1.0

1. Foreword Zedball is a sports entertainment platform where players (“you,” or “User”) can engage with their favourite athletes and build connections with their friends and the world-wide sports community. We respect your privacy and are committed to providing a secure environment to our Users. This privacy policy (“Policy”) is intended to provide you with important information about how and why your data may be collected and processed by Zedball (“we,” “us” or “Zedball”). All Personal Data (defined below) will be processed pursuant to applicable law, including the European Union’s General Data Protection Regulation, federal and State law in the United States governing personal data protection, and other applicable data protection laws. This Policy is part of the Terms and Conditions, as it is set forth directly therein. By using our Products you acknowledge that you have read and understood the terms of this Privacy Policy, including how we use your personal data.

2. Data Collected and Purposes We collect and process a limited amount of Personal Data for specific purposes, such as allowing you to access the Services, making the Services fun and easy to use, improving your experience and preventing fraud. Whenever we collect your Personal Data, and for whatever purposes, we are committed to always collecting the minimum amount of Data that is necessary for the relevant purpose. This section provides more information regarding what Personal Data we collect, what we process that Personal Data for and the legal basis for each specific processing purpose. Account Information. Zedball collects and processes Data to allow you to create and access your User account. In order to manage your User account from creation to deletion, you must provide us with some information about yourself (i.e. your first name, last name, username, email address and for some operations your phone number for identity verification purposes). You will also be able to store your personal settings, preferences and favourite teams or players on your general User account and/or through your browser and device. In order to store these, Zedball will associate your choices with your User account, technical identifiers, browser and/or device. The legal basis of this processing is contractual. We require this data in order to create and maintain your User account, execute the Terms and Conditions, and any other applicable Additional Terms that you agreed to when signing up for your User account. Website and Mobile Application Use. Zedball collects and processes some Data in order to understand how Users actually interact with the Services and improve User experience. This Data consists of various browsing information derived from Cookies or technical mobile identifiers (see the Cookie Policy), some of which may include Personal Data. The legal basis of this processing depends on your location and the applicable law. In countries where the use of cookies is conditioned on the Users’ prior consent, Zedball processes this Data on the basis of your consent. In other countries, Zedball processes this Data on the basis of (i) its legitimate interest, including understanding the way its Services are used by Users; and improving the Services if needed, or (ii) your consent, depending on the purpose of the cookie. Access to and Use of the Services. Zedball collects and processes Personal Data in order to allow you to access and use the different parts of the Services, including to facilitate the purchase of a Collectible and to play the Game. Terms Compliance; Website and Account Security. Zedball collects certain device and browser information (user agent), browsing data, including IP address (from which information on your country/state of location can be inferred), account information (including your email address and phone number) and transaction details, to ensure the security of the Services and your User account, and to detect, prevent, investigate, and/or trace any attempt to violate our Terms and Conditions or any other Applicable Terms, such as by malicious hacking. In the course of an investigation, Zedball may take additional security measures, including but not limited to requesting additional supporting documents and/or information, or suspending or canceling the relevant transaction in the event the transaction cannot be verified. Where payment fraud has been investigated and confirmed, the relevant Data and other related information will be stored in Zedball’s monitoring system and used for future verifications. The legal basis of this processing is Zedball’s legitimate interest. Zedball has a legitimate interest in detecting, preventing, and investigating fraud to ensure a fair game for all users and to protect its Services and Users against potential credit card frauds. User Requests and Communication. Zedball collects and processes Personal Data, such as your username, contact details, and the content of your message (to the extent such content is considered Personal Data) when managing and following up on any questions and/or requests you may submit via our Help Center or other method. The legal basis of this processing is contractual. Support is integral to the Services we provide, so we require this data in order to execute the Terms and Conditions, and any other applicable Additional Terms, that you agreed to when signing up for your User account.

3. Blockchain Technology and Your Data NFT. Blockchain is at the core of the Services that Zedball provides. This technology in the form of non-fungible-tokens (NFT) creates the verifiable authenticity, scarcity, and interoperability of your Collectibles. Your data. Your wallet public key and the information related to your purchases, transfers, withdrawals, and exchanges of Collectibles are stored on our Heroku Servers and our data availability committee whose members ensure the back-up of this information and are committed to strict confidentiality obligations. No Personal Data of our Users is stored by Zedball on the public Ethereum blockchain. However, please note that if you withdraw your funds or a Collectible from your Wallet (for instance to transfer them to another service or to an external wallet), such transfer will involve the storage of the information related to this transfer on a public blockchain. All transfers to external wallets are subject to the relevant Third-Party Service’s privacy policy and/or terms of service, please make sure to review the privacy policies and practices of the third parties involved before you proceed with such transfer. As indicated in our terms and conditions Zedball will not be held liable for any third-party content or service and disclaims all responsibility for any and all services provided to a User by a third-party service provider. The legal basis of this processing is contractual. The blockchain is at the core of our services. This is what allows Zedball to offer verifiable authenticity, scarcity, and interoperability of your Collectibles.

4. Data Retention Account Information. Zedball will keep your Personal Data until the closure of your account. However, where required or allowed by applicable law, if Zedball needs to retain certain Personal Data beyond the date of closure of your account, then the maximum applicable retention period will apply, pursuant to the applicable statutory limitation periods. This period will not exceed the period for which the Company must retain the Data. Website Use. Personal Data processed by or on behalf of Zedball for the purposes of analytics or other study or analysis will not be retained by Zedball after such studies have been completed and the relevant reports, outputs and/or insights have been produced. Access to the Services. Personal Data processed for the use of the Services will only be kept for fifteen (15) months from the date of the relevant activity. Blockchain Technology. Personal Data processed and logged on a blockchain in connection with your transactions on Zedball will be stored in an immutable way. Please see “Blockchain technology” section above to better understand what categories of information are logged on the public Ethereum blockchain and what measures have been implemented by Zedball to protect your Personal Data. Terms Compliance. Website and Account Security. Personal Data processed for fraud prevention will be kept for three (3) years after the relevant data has been included on an alert list. Personal Data processed for security matters will be kept for five (5) years from the last account login or suspicious activity. User Requests and Communication. For management of your questions and/or requests, Zedball will retain your Personal Data for a maximum of three (3) years after the last time you reached out to us. Notwithstanding the above, Zedball may store some Personal Data for a longer duration pursuant to its legitimate interests and applicable legal obligations. When the relevant retention period expires, Zedball will delete your Personal Data or apply adapted measures to the relevant data to ensure that you can no longer be identified. If Zedball concludes that it is not necessary to keep your Personal Data in its active database, it will archive the relevant Data. For all active and archived Data, Zedball will ensure that access to the relevant Data is restricted to a limited number of persons with a genuine need to access it.

5. Processors and Data Transfer Zedball may use Third-Party Service providers and other third parties (“Processors”) to facilitate, maintain, improve, analyze, and secure the Website, App, and Services. Processors may have access to Personal Data for the sole and exclusive purpose of carrying out the processing activity assigned to the relevant Processor by Zedball. Zedball ensures that the service providers have sufficient guarantees for the performance of the processing activity and comply with the applicable laws and regulations. Personal Data may be processed outside the European Economic Area (“EEA”). When Data is transferred outside of the EEA, Zedball will take all necessary precautions, and alternatively or cumulatively: (i) ensure that the European Commission has taken an adequacy decision regarding the country of destination, (ii) that model contractual clauses adopted by the European Commission or the supervisory authority have been signed with the recipient, (iii) that the recipient adhered to an approved code of conduct or certification mechanism, etc.

6. Data Sharing The Company shares your Personal Data with Third-Party Service providers and suppliers which assist the Company for fulfilling the purposes specified in this Policy. Zedball’s API At Zedball, we are committed to providing an open platform for our community of Users and developers to build upon new services, games, or applications. To this end, we provide access to an Application Programming Interface (API) allowing authenticated and authorised users to access more conveniently to some public Users’ information published on Zedball’s Website: Basic User information, including their username, avatar, and wallet address, User’s cards, achievements, and favourites, Users’ auctions, offers, purchases, sales, and notifications. Please note that the following information is never shared through our API: Email address, Future lineups and rewards, Claiming rewards. Third-Party Services Some content or features of the Website and/or App are provided by Third-Party Service providers. In order to facilitate your access to such content and/or features, Zedball may share some of your Personal Data with Third-Party Services and suppliers. The Third-Party Service may ask you for additional Data. Whether or not integrated into the Website and/or App directly, these Third-Party Services collect and process any Data they receive pursuant to their relevant privacy policy, in that provider’s sole responsibility. Please note that the contractual arrangements between Zedball and our Third-Party Service Providers (such as payments services providers or marketing partners) specify that both Zedball and the Third-Party Service Provider will act as an “independent controller” as defined by the GDPR (or “Business” as defined by the CCPA) and must comply with all applicable data protection laws and regulations. Please consult the relevant privacy policy of the relevant Third-Party Service for more information. Partner Sports Leagues, Teams, and Clubs Our partner sports leagues, teams and clubs (“Partner(s)”) make Zedball great. Zedball may share your email address and username with these trusted Partners for the relevant Partner’s own direct marketing and promotional purposes. During User account registration, you can choose if you consent to us sharing such Data with our Partners or not. This is totally up to you - If you do not consent, we will not share the Data. If you do consent, please note that the contractual arrangements between Zedball and its Partners specify that both Zedball and each Partner will act as an “independent controller” as defined by the GDPR (or “Business” as defined by CCPA) and must comply with all applicable data protection laws and regulations. Please consult the relevant privacy policy of the relevant Partner for more information. Judicial and Governmental Authorities Where required by law or valid court order and to the extent legally permitted, Zedball may share your Personal Data with competent courts and/or any other governmental and/or public authorities requesting access to your Personal Data. We take sharing your Data seriously. Whenever we share your Personal Data with any of the above recipients, we do so on a strictly need-to-know basis and only as necessary for fulfilling identified processing purposes.

7. Use by Children The Website, App, and Services are intended for use by individuals eighteen (18) years old or older. Pursuant to the Terms and Conditions, the Website, App and Services are not available for Users under 18 years old.

8. Your Rights Most applicable data privacy laws (including the European Union’s GDPR, and some American states’ laws, including but not limited to the CCPA) have granted individuals rights in connection with their Data and how that Data is processed. The below section is intended to inform you of your rights in connection with your Personal Data. Please note that all requests pursuant to this section will be processed in accordance with the applicable European laws (notably GDPR) disregarding your location or country of residence but our answers may be adapted to comply with local laws requirements. You have the right to access your Personal Data, correct it, move it, delete it and a right to restrict how your Data is processed. You also have the right to specify instructions defining the way Personal Data shall be managed after your death. Requests To exercise your rights or make an enquiry regarding data privacy at Zedball, you should make a request accompanied by proof of identity by email at [email protected] Zedball will attempt to answer your request or enquiry as soon as possible, and at the latest within one (1) month of receipt of the request. For complex requests, we reserve the right to extend this period to three (3) months. If you remain unhappy with a response you receive, you can also refer the matter to your data protection supervisory authority (see - for Europe, or - for the United Kingdom). Deletion of User account If you intend to request the deletion of your Personal Information you can use the method described above or simply request the deletion of your User account via the settings of your User account as described in Zedball’s terms and conditions. The deletion of your account will result in the irreversible deletion of the Personal Data associated with the account. To ensure the respects of your rights without altering the history and traceability of each Collectible you owned, the username associated with the ownership of these Collectibles will be pseudonymized and replaced by a random series of alphanumeric characters. You must save any Collectibles and Cryptocurrencies stored on the Wallet to an external wallet before any deletion request. Any Collectibles and/or Cryptocurrency stored on your Wallet that have not been transferred out of your account at the date of deletion will be permanently irretrievable. Zedball will not be responsible for the permanent loss of any Collectibles and/or Cryptocurrency that was not saved prior to a deletion request. Protecting your Personal Data and complying with the applicable data protection legal framework are two of Zedball’s top priorities and we need your help to be successful. By agreeing to this Policy, you agree to keep your Data on Zedball up-to-date, and only provide accurate and current Personal Data. Additionally, if you send us any information that would allow us to identify, directly or indirectly, any other individuals, you represent and warrant that, prior to sharing this information, such other natural persons have been provided with this Policy and, to the extent applicable, have consented to the processing of their Data.

9. Cookies When you browse our Website, cookies are placed on your terminal, either directly or after having obtained your consent when required by the regulations on cookies. Cookies are pieces of information placed on the Internet user's terminal equipment by the server of the website visited. They are used by a website to send information to the Internet user's browser and to allow this browser to send information back to the website of origin (for example, a session identifier or the choice of a language). Only the sender of a cookie can read or modify the information contained in it. There are different types of cookies: session cookies that disappear as soon as you leave the Website; permanent cookies that remain on your terminal until their lifetime expires or until you delete them using your browser's functions. You are informed that, during your visits to the Website, cookies may be installed on your terminal equipment. To learn more about the use of cookies on our Website, please see the cookie policy here: Zedball Cookie Policy.

10. Security Zedball has implemented and maintains measures to protect the confidentiality, security, and integrity of your User account and Personal Data against unauthorised access and disclosure, modification, alteration, damage, accidental loss or accidental or illicit destruction, as well as against any other form of unauthorised processing or disclosure. We recommend you observe security best practices, including storing your account information securely and not sharing account information. Please note that our backup services will not make a backup of your data to your personal, local storage or drive; we recommend you use a secondary backup source and/or other best practices for the preservation of data. Additionally, we recommend you enable two-factors-authentication, choose a strong password and/or use a password manager for any and all password protected features of your User account and your User account itself. Zedball recognises the importance and value of security researchers’ efforts in helping keep our community safe. We encourage responsible disclosure of security vulnerabilities to our support team at [email protected]

11. Updates to this Privacy Policy Zedball reserves the right to change this Policy as necessary, as the Service evolves or as required by applicable laws. Any material Policy changes will be communicated to you. When using the Services, you are deemed to have accepted the terms of the Policy, as published on our Website.