Voono is an interactive sports entertainment platform where sports enthusiasts ("you," or "User") can engage with your favourite athletes and teams while connecting with the worldwide sports community. We prioritise your privacy and strive to create a secure space for our Users. This confidentiality statement ("Statement") aims to inform you about the collection and processing of your data by Voono ("we," "us," or "Voono"). All Personal Data (defined below) will be handled according to relevant laws, including the European Union's General Data Protection Regulation, federal and state laws in the United States governing personal data protection, and other applicable data protection regulations. This Statement is incorporated into the Terms and Conditions. Capitalised terms not explicitly defined here shall have the meaning assigned to them in the Terms and Conditions.

We collect, store and use a limited amount of Personal Data for specific objectives, such as granting you access to the Services, enhancing the usability of the Services, improving your experience, and preventing fraud. In accordance with the UK’s Data Protection Act 2018 and the GDPR, whenever we collect your Personal Data, and for whatever reasons, we are dedicated to always collecting the least amount of Data necessary for the relevant purpose.

This section offers additional information about the types of Personal Data we collect, the processing purposes, and the legal basis for each specific processing objective.

• Account Details. Voono collects and processes Data to enable you to create and access your User account. To manage your User account from inception to deletion, you must provide us with certain information about yourself (e.g., your first name, last name, username, email address and phone number). You can also save your personal settings, preferences, and favourite teams or players on your general User account and/or through your browser and device. Voono associates your choices with your User account, technical identifiers, browser, and/or device to store these details.

• The legal basis for this processing is contractual. We need this data to establish and maintain your User account, execute the Terms and Conditions, and any other relevant Additional Terms that you agreed to when registering for your User account.

• Usage of Website. Voono gathers and processes some Data to comprehend how Users engage with the Services and enhance User experience. This Data consists of various browsing information obtained from Cookies or technical mobile identifiers (refer to the Cookie Policy), some of which may comprise Personal Data.

• The legal basis for this processing depends on your location and the applicable law. In countries where the use of cookies is contingent on the Users' prior consent, Voono processes this Data based on your consent. In other countries, Voono processes this Data on the grounds of (i) its legitimate interest, including understanding how its Services are utilised 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. Voono collects and processes Personal Data to grant you access to and use the various aspects of the Services, including facilitating the acquisition of a Collectible, engaging in the Game, or participating in our Referral Programs.

• To buy a Collectible on the Primary Market and/or purchase, transfer, withdraw, and/or exchange a Collectible via the Marketplace, Voono collects your username, phone number, or payment identifier and has access to a portion of your credit card number (e.g., the last four digits of the credit card that we can access through payment service providers but do not directly collect or store).

• To facilitate participation in a Tournament, send prizes to the winners, publish leaderboards, and more, Voono processes your username and the prize(s) you have won (where applicable). Voono may publish your username and the prize(s) you have won on its Website, as part of the leaderboard presenting the results of the tournaments.

• To allow participation in our Referral program, Voono collects and processes your email address, username and the referral code specific to your user profile.

• The legal basis of this processing is contractual. We require this data to execute the Terms and Conditions, and any other applicable Additional Terms, that you agreed to when signing up for your User account.

• Terms Compliance; Website and Account Security. Voono 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, Voono may take additional security measures, including but not limited to requesting additional supporting documents and/or information, or suspending or cancelling 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 Voono’s monitoring system and used for future verifications.

• The legal basis of this processing is Voono’s legitimate interest. Voono 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. Voono 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 help@voono.io.

• The legal basis of this processing is contractual. Support is integral to the Services we provide, so we require this data to execute the Terms and Conditions, and any other applicable Additional Terms, that you agreed to when signing up for your User account.

• Data Transfers Outside the EEA: Voono may transfer your personal data outside of the European Economic Area. When we do so, we ensure that appropriate measures are in place to protect your personal data and to comply with our obligations under applicable data protection law. This may include entering into contracts in the form approved by the European Commission, or ensuring that the company to which we transfer your personal data has agreed to abide by an approved transfer mechanism, such as the EU-US Privacy Shield.

Despite the above, Voono may store some Personal Data for longer durations due to its legitimate interests and applicable legal obligations. Upon the expiration of the relevant retention period, Voono will delete your Personal Data or implement adapted measures to ensure that you can no longer be identified. If Voono determines that retaining your Personal Data in its active database is unnecessary, it will archive the pertinent Data. For all active and archived Data, Voono will ensure access to the relevant Data is restricted to a limited number of individuals with a genuine need for access.

Voono may utilise Third-Party Service providers and other third parties ("Processors") to facilitate, maintain, improve, analyse, and secure the Website, App, and Services. Processors may access Personal Data exclusively for the purpose of performing the processing activity assigned to the respective Processor by Voono. Voono ensures that the service providers offer sufficient guarantees for executing 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, Voono will take all necessary precautions and, alternatively or cumulatively: (i) ensure that the European Commission has made an adequacy decision regarding the destination country, (ii) sign model contractual clauses adopted by the European Commission or the supervisory authority with the recipient, (iii) ensure that the recipient adhered to an approved code of conduct or certification mechanism, etc.

The Company shares your Personal Data with Third-Party Service providers and suppliers to help the Company achieve the purposes outlined in this Policy.

If you do consent, please note that the contractual arrangements between Voono and its Partners specify that both Voono 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 corresponding Partner for more information.

The Website, App, and Services are designed for use by individuals who are eighteen (18) years old or older. As per the Terms and Conditions, the Website, App, and Services are not available to Users under 18 years of age.

Most applicable data privacy laws (including the European Union's GDPR, and some American states' laws, such as the CCPA) grant individuals rights concerning their Data and how that Data is processed. The following section aims to inform you of your rights concerning your Personal Data. Please note that all requests under this section will be processed according to applicable European laws (mainly GDPR) regardless of your location or country of residence, but our responses may be adapted to comply with local law requirements.

You have the right to access your Personal Data, correct it, move it, delete it, and the right to restrict how your Data is processed. You also have the right to specify instructions defining how Personal Data should be managed after your death.

Protecting your Personal Data and complying with the applicable data protection legal framework are two of Voono's top priorities, and we need your help to be successful. By agreeing to this Policy, you agree to keep your Data on Voono up-to-date and provide only 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, before 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.

Our Services utilise cookies and similar technologies to distinguish you from other users and to gather certain personal data about you. A cookie is a small file stored on your device, containing information transferred to your device's storage.

By using our Services, you're consenting to our use of cookies as described in this clause. You have the right to withdraw this consent or modify your cookie preferences at any time.

We utilise different types of cookies:

The duration of cookie storage varies. Session cookies are temporary and expire when you exit our website or close your browser. Persistent cookies remain for a predetermined period, allowing our Services to recognize your device on return visits.

You can manage cookies through your browser settings, including refusing or being alerted about new cookies. Disabling cookies may affect our Services' functionality.

This Cookie Use Clause may be updated periodically due to legal, technical, or business developments. You'll be informed appropriately of any significant changes.

Voono 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 use a password manager for any and all password-protected features of your User account and your User account itself.

Voono 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.

Voono 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.

Subject to applicable law, you agree that the courts of England and Wales will have exclusive jurisdiction over any dispute arising out of or relating to this Policy. However, if you are a consumer and resident of any European Union country, you will benefit from mandatory provisions of, and legal rights available to you under, the laws of that country. Nothing in this Policy affects your rights as a consumer to rely on these local law mandatory provisions and legal rights.

Subject to applicable law, you agree that the courts of England and Wales will have exclusive jurisdiction over any dispute arising out of or relating to this Policy. However, if you are a consumer and a resident of another country in the European Union, you may also have the right to bring proceedings in your resident country.