Please read these Terms of Use and the Risk Disclosure Statement carefully. By clicking the “Start trading now” button or by accessing or using any service made available by us, you agree to be legally bound by these Terms of Use (including the Fee Structure and Risk Disclosure Statement), the Privacy Policy and all terms incorporated by reference in the foregoing.

Summary of Terms of Use

We, PlayBits (hereinafter referred to as “we” or “us”), summarize below our Terms of Use to give an overview of the key terms that apply to your use of our website and trading services. While we hope this summary section is helpful, you must read the complete Terms of Use below since they provide important information about our services, our respective legal rights and obligations, and the risks involved in trading in cryptographic tokens.

Our Services

We provides you with a simple and convenient way to trade one type of Digital Token for another type of Digital Token. PlayBits provides you with a platform that matches your orders with open orders from other users of our Services. Users are not able to predetermine a trade with a particular user or with a particular account. Additionally, an order may be partially filled or may be filled by multiple matching orders. As of today, PlayBits does not provide services for the trading of legal tender  (“Fiat Currency”) for Digital Tokens or vice versa. PlayBits does not provide services for the trading of one type of Fiat Currency for another type of Fiat Currency.

Eligibility and Acceptable Use

You must meet certain eligibility criteria to use PlayBits services. You must be at least 18 years of age and there are certain locations from which you may not be able to use some or all of PlayBits services. Other eligibility criteria may also apply. Additionally, there are certain things you cannot do when using PlayBits services, such as engage in market misconduct or illegal activities, lie, or do anything that would cause damage to our services or systems. Please see Section 12 below on “Acceptable Use” for more details.

Trading Risks

Engaging in trades in cryptographic tokens may be highly risky. Please do not use PlayBits services for trading in Digital Tokens if you do not understand these risks.

 

Other Important Legal Terms

There are important legal terms provided below in the complete Terms of Use, including your indemnification responsibilities, our limitation of liability and warranty disclaimers, and your agreement to arbitrate disputes. Please take the time to read these terms carefully. You can always contact us through PlayBits Help Center if you have any questions.

Complete Terms of Use

These Terms of Use and any terms expressly incorporated herein (“Terms”) apply to your use of the website operated and maintained by PlayBits (collectively, “PlayBits”, “we”, or “us”), and the trading services provided by PlayBits as described in these Terms (collectively, our “Services”).

 

1. Key Definitions

Capitalized terms not otherwise defined in these Terms will have the following meaning:

1.1.“External Account” means any Digital Token Account: (i) from which you may transfer Funds into your PlayBits Account, and (ii) to which you may transfer Funds from your PlayBits Account and which has been approved by PlayBits for the foregoing purposes.

1.2.“Funds” means Digital Tokens.

1.3.“Fiat Currency” means any national currency.

1.4.“PlayBits Account” means a user account accessible via the Services where Funds may be stored by PlayBits on behalf of a user.

1.5.“Digital Tokens” means Bitcoins, PlayBits Tokens, Ripples and other digital mediums of exchange that may be purchased, sold or traded via the Services.

1.6.“Digital Token Account” means any Digital Token address or account owned or operated by you that is maintained outside of the Services, and is not owned, controlled or operated by PlayBits.

 

2. Eligibility

2.1. PlayBits may not make the Services available in all markets and jurisdictions, and may restrict or prohibit use of the Services from certain jurisdictions (“Restricted Locations”).

2.2. You further represent and warrant that you: (a) are at least 18 years old; (b) have not previously been suspended or removed from using our Services or other similar services provided by other parties; (c) have full power and authority to enter into these Terms and in doing so will not violate any other agreement to which you are a party; (d) using our platform in your own name and solely for your own benefit; (e) are not located in, under the jurisdiction of, or a national or resident of any Restricted Locations (as defined in Section 2.1 above); (f) will not use our Services if any applicable laws in your country prohibit you from doing so in accordance with these Terms; (g) are not a designated person under regulations issued pursuant to the lists of individuals or entities identified by the Security Council of the United Nations or the Committee as individuals or entities to whom or which apply the measures referred to in paragraph 8(d) of Resolution 1718 (2006)(including any such list as updated from time to time by the Security Council or the Committee, and made available on the Internet through the official United Nations website at http://www.un.org/) ; and (h) have read and understood these Terms and the Risk Disclosure Statement.

2.3. PlayBits maintains an anti-money laundering, countering the financing of terrorism and know your customer compliance policy (the “AML/CFT Policy”). Pursuant to such policy, PlayBits may, in its discretion, require identity verification and go through other screening procedures with respect to you or transactions associated with your PlayBits Account. You agree and undertake to provide PlayBits with any and all information and documents that PlayBits may from time to time request or require for the purposes of these Terms or in connection with your PlayBits Account (including, but not limited to, your name, address, telephone number, email address, date of birth, government-issued identification number, photograph of your government-issued identity card or document or other photographic proof of your identity, and information regarding your Digital Token Account). PlayBits will have no liability or responsibility for any permanent or temporary inability to access or use any Services as a result of any identity verification or other screening procedures.

Further, pursuant to the AML/CFT Policy, PlayBits may, in its discretion, carry out continuous monitoring of all PlayBits Accounts. If any unusually large or unusual patterns of trades or any inexplicable or suspicious circumstances are observed, PlayBits may, in its discretion, place an administrative hold on or freeze your PlayBits Account. You agree that PlayBits will have no liability or responsibility for any permanent or temporary inability to access or use any Service caused by such action.

2.4. Additionally, by agreeing to these terms you certify that you pursue participation in blockchain-based networks as a part of your professional activity and are familiar with digital tokens or cryptographic tokens and trading in them and the risks attached to them and their trading, including but not limited to the risks highlighted in the Risk Disclosure Statement.

 

3. PlayBits Account

3.1. Number of PlayBits Accounts. PlayBits may, in its sole discretion, limit the number of PlayBits Accounts that you may hold, maintain or acquire.

3.2. PlayBits Account information and security. In order to engage in any trades via the Services, you must create a PlayBits Account and provide any requested information. When you create a PlayBits Account, you agree to: (a) create a strong password that you do not use for any other website or online service; (b) provide accurate, complete and truthful information; (c) maintain and promptly update your PlayBits Account information; (d) maintain the security of your PlayBits Account by protecting your password and restricting access to your PlayBits Account; (e) promptly notify us if you discover or otherwise suspect any security breaches related to your PlayBits Account; and (f) take responsibility for all activities that occur under your PlayBits Account and accept all risks of any authorized or unauthorized access to your PlayBits Account, to the maximum extent permitted by law.

3.3. You are solely responsible for doing all things and taking all actions necessary to monitor and secure your PlayBits Account, and to enable or receive financial or other benefits made available to Digital Token holders.

3.4. You must not create security or any other collateral interest over the Funds in your PlayBits Account except with our prior written consent.

4. Privacy Policy

Please refer to our Privacy Policyfor information about how we collect, use and disclose your personal data.

5. General Obligations

This Section 5 applies to: (i) all trades completed via the Services, and (ii) any transaction in which you transfer Funds into your PlayBits Account from your External Account or transfer Funds from your PlayBits Account into an External Account.

5.1. Conditions and Restrictions. We may, at any time and in our sole discretion, refuse any trade submitted via the Services, impose limits on the trade amount permitted via the Services or impose any other conditions or restrictions upon your use of the Services without prior notice. For example, we may limit the number of open orders that you may establish via the Services or we may restrict trades from certain locations.

5.2. Accuracy of Information. You must provide any information required when creating a PlayBits Account or when prompted by any screen displayed within the Services. You represent and warrant that any information you provide via the Services is accurate and complete.

5.3. Cancellations.

Cancellation of orders. You may only cancel an order initiated via the Services if such cancellation occurs before PlayBits executes the transaction. Once your order has been executed, you may not change, withdraw or cancel your authorization for PlayBits to complete such transaction. If an order has been partially filled, you may cancel the unfilled remainder. We may cancel your order in the following circumstances: (i) you have, in our view, engaged in market manipulation or abuse (as described in Section 12.1 below); (ii) your order under the circumstances involves an obvious error with respect to price, quantity or other parameters; (iii) your order would result in self-execution as described in Section 7.1 below;(iv) if required by any applicable law or regulation; and/or (v) if required for technical reasons, such as system maintenance and/or upgrade.

Cancellation of trades. Subject to Section 7.7 below, in contrast to exchange orders, all trades are irreversible once initiated. While we may, at our sole discretion, reverse a trade in the case of Manifest Error or if required by any applicable law or regulation or under certain extraordinary conditions, a customer does not have a right to a reversal of a trade.

5.4. Insufficient Funds. If you have an insufficient amount of Funds in your PlayBits Account to complete an order via the Services, we may cancel the entire order or may fulfill a partial order using the amount of Funds currently available in your PlayBits Account, less any fees owed to PlayBits in connection with our execution of the trade (as described in Section 9 below).

5.5. Taxes. It is your responsibility to determine what, if any, taxes apply to the trades you complete via the Services, and it is your responsibility to report and remit the correct tax to the appropriate tax authority. You agree that PlayBits is not responsible for determining whether taxes apply to your trades or for collecting, reporting, withholding or remitting any taxes arising from any trades.

5.6. Compliance with all applicable laws and regulations. You represent, warrant and undertake that you have and shall at all times comply with all applicable laws and regulations in all jurisdictions relevant to any Service provided or made available by us to you.

 

6. PlayBits Account Funds

6.1. Transferring Funds to your PlayBits Account. In order to place or match an order or trade via the Services (as described in Section 7), you must first transfer Funds to your PlayBits Account using one of the approved External Accounts identified via the Services. You may be required to verify that you control the External Account that you use to load Funds to your PlayBits Account. You may be charged fees by the External Account you use to transfer Funds to your PlayBits Account. PlayBits is not responsible for any External Account fees or for the management and security of any External Account. You are solely responsible for your use of any External Account, and you agree to comply with all terms and conditions applicable to any External Account. The timing associated with a transaction for the transfer of Funds to or from an External Account will depend in part upon the performance of third parties responsible for maintaining the applicable External Account, and PlayBits makes no guarantee regarding the amount of time it may take to transfer Funds into your PlayBits Account.

6.2. Transferring Funds to an External Account. Provided that the balance of Funds in your PlayBits Account is greater than any minimum balance requirements needed to satisfy all of your open orders and trades and any fees payable to PlayBits, and subject to your compliance with all identity verification and other screening procedures and your satisfaction of all requirements under PlayBits’s AML/CFT Policy as provided in Section 2.3 above, PlayBits may (but is not obligated to) agree to your request to transfer any amount of Funds, up to the total amount of Funds in your PlayBits Account in excess of such minimum balance requirements, from your PlayBits Account to an External Account, less any fees charged by PlayBits for such transactions (as described in the Fee Structure at the time of your request to transfer Funds to an External Account).

6.3. Transfer Authorization. When you request that we transfer Funds into your PlayBits Account from your External Account or request that we transfer Funds to your External Account from your PlayBits Account, you authorize PlayBits to execute such transaction via the Services.

6.4. Rejected Transactions. In some cases, the External Account may reject your Funds or may otherwise be unavailable. You agree that you will not hold PlayBits liable for any loss resulting from such rejected transactions.

6.5. Ownership of Digital Tokens. You hereby represent and warrant that any Digital Tokens transferred to your PlayBits Account from an External Account or otherwise used by you in connection with the Services are owned by you legally and beneficially, and that all orders, trades and transactions initiated with your PlayBits Account are for your own account and not on behalf of any other person or entity.

 

7. Exchange Orders and Trades

This Section applies when you use the Services to trade one type of Digital Tokens for another type of Digital Tokens. A trade is a binding agreement between you and another user to exchange an agreed amount of one form of Digital Tokens, for an agreed amount of another form of Digital Tokens, which exchange is supported by the Services and which is in accordance with these Terms. PlayBits does not purchase, sell, or exchange any Digital Tokens on its own behalf, does not provide services for the trading of Digital Tokens for Fiat Currency and vice versa, and does not provide services for the trading of one Fiat Currency for another Fiat Currency.

7.1. Order Placement, Authorization. An order is created when you enter an instruction to buy or sell a specified quantity of a type of Digital Token at a specified price. To place an order, you must have a sufficient amount of the relevant Funds in your PlayBits Account to cover the total value of the order plus any applicable fees (as described in Section 9 below).

You are not able to place an order which would result in self-execution, that is, where you would act as both the buyer and seller in respect of the same trade. If two orders of the same quantity would result in self-execution, both orders are cancelled.

When you submit a new order via the Services, and it is matched with another order and it results in a trade under the Services, you will be deemed to have authorized PlayBits to execute and settle the trade in accordance with such order on a spot basis and charge you any applicable fees (as described in Section 9 below).

7.2. Modes of Orders. We provide different modes of orders for your options as described below. For the purpose of description, the terms shall bear the below meanings:

Targeted Token: the type of Digital Token you intended to trade upon placement of an order or orders.

Latest Market Price: the latest unit price of the Targeted Token when the order placed by you shall be executed;

Specified Price: the unit price of the Targeted Token, which is preset by you and shall be the final executed unit price of the Targeted Token.

Specified Quantity: the quantity of the Targeted Token, which is preset by you and shall be the final executed quantity of the Targeted Token.

7.3. Market rates. You acknowledge and agree that (i) the exchange rate information made available via our Services may differ from prevailing exchange rates made available via other sources outside of the Services; (ii) an order may be matched with other order(s) at a number of different prices, based on the quantity of the order and the quantities of existing orders on the order book at the time; and (iii) depending on the volume and prices of orders on the order book at the time when an order is placed, the order may be matched with another order at a price less favorable than the most recent trade price, in some cases significantly so.

7.4. Market volatility. Particularly during periods of high volume, illiquidity, fast movement or volatility in the marketplace for any particular, or one or more Digital Tokens, the actual market rate at which a trade is executed may be different from the prevailing rate indicated via the Services at the time of your order or trade. You understand that we are not liable for any such price fluctuations. In the event of a market disruption or Force Majeure event (as defined in Section 22), PlayBits may do one or more of the following: (a) suspend access to the Services; or (b) prevent you from completing any actions via the Services, including closing any open positions. Following any such event, when trading resumes, you acknowledge that prevailing market rates may differ significantly from the rates available prior to such event.

7.5. Trade Settlement. Subject to the terms and conditions in these Terms, we will use commercially reasonable efforts to settle trades on a spot basis within two (2) days of the date of the execution of a user’s trade via the Services.

7.6. Error Correction Attempts. A Manifest Error is an error or omission, which by fault of you or us or any user or third party or due to any disruptions, errors, distortions or delays, is materially and clearly incorrect when taking into account market conditions, rates and prices which prevailed at that time. It may include, but is not limited to, an incorrect price, date, time, Digital Token pair, fee, or any error or lack of clarity of any information or source.

If an order, trade or transfer is based on a Manifest Error (regardless of whether you or we or any other user gains from the error) and/or executed and/or settled on the basis of Manifest Error, PlayBits may (but is not obliged to), at its option and sole discretion, act reasonably and in good faith to: (a) correct, reverse or cancel any order, trade or transfer; (b) void a trade as if it had never taken place; and/or (b) amend a trade so that its terms are the same as the trade which would have been executed if there had been no Manifest Error.

We will exercise the foregoing rights as soon as reasonably practicable after we become aware of the Manifest Error. To the extent practicable we will give you prior notice of any action we take under this clause but if this is not practicable we will give you notice as soon as practicable afterwards. If you consider that an order, trade or transfer is based on a Manifest Error, then you must notify us immediately. We will consider in good faith whether it is appropriate to take any action under this Section 7.7 taking into account all the information relating to the situation, including market conditions and your level of expertise.

You hereby authorize PlayBits to attempt and/or perform any such correction, reversal, cancellation, voiding or amendment described in this section. PlayBits provides no guarantee or warranty that any such attempt will be successful and will have no responsibility or liability for the Manifest Error or the making or failure of any correction attempt, except if caused by the gross negligence, willful default or fraud of PlayBits. There is a risk that you may be prejudiced by any action or omission of PlayBits in this regard, and you accept that you have no recourse whatsoever against PlayBits.

7.7. Independent Relationship, No Advice. You acknowledge and agree that: (a) PlayBits is not holding monies and/or Funds as your trustee, and is not acting as your broker, intermediary, agent, or advisor or in any fiduciary capacity, and (b) no communication or information provided to you by PlayBits shall be considered or construed as advice.

We shall not give advice to you on the merits of any trade and shall deal with you on an execution-only basis. None of our employees or staff are authorised by us to give you investment advice. Accordingly, you should not regard any proposed trades, suggested trading strategies or other written or oral communications from us as investment recommendations or advice or as expressing our view as to whether a particular trade is suitable for you or meets your financial objectives. You must rely on your own judgement for any investment decision you make in relation to your PlayBits Account. If you require investment or tax advice, please contact an independent investment or tax adviser. You acknowledge and agree that you have made your own independent analysis and decision when executing a trade and such trades are entered into without reliance upon any views, representations (whether written or oral), advice, recommendation, information or other statement by us.

 

8. Risk Disclosure

Please refer to the Risk Disclosure Statement.  

 

9. Fees

9.1. Amount of Fees. You agree to pay the fees for trades completed via our Services (“Fees”) as made available via the Fee Structure, which we may change from time to time. Changes to the Fee Structure are effective as of the effective date indicated in the posting of the revised Fee Structure to the Services, and will apply prospectively to any trades that take place following the effective date of such revised Fee Structure.

9.2. Third-Party Fees. In addition to the Fees, your External Account may impose fees in connection with your use of your designated External Account via the Services. Any fees imposed by your External Account provider will not be reflected on the transaction screens containing information regarding applicable Fees. You are solely responsible for paying any fees imposed by an External Account provider.

9.3. Payment of Fees. You authorize us, or our designated payment processor, to charge or deduct your PlayBits Account Funds for any applicable Fees owed in connection with trades you complete via the Services.

 

10. Electronic Notices

10.1. Consent to Electronic Delivery. You agree and consent to receive electronically all communications, agreements, documents, receipts, notices and disclosures (collectively, “Communications”) that PlayBits provides in connection with your PlayBits Account and/or use of the PlayBits Services. You agree that PlayBits may provide these Communications to you by posting them via the Services, by emailing them to you at the email address you provide. You should maintain copies of electronic Communications by printing a paper copy or saving an electronic copy. You may also contact us through support to request additional electronic copies of Communications or, for a fee, paper copies of Communications (as described below).

10.2. Hardware and Software Requirements. In order to access and retain electronic Communications, you will need a computer with an Internet connection that has a current web browser with cookies enabled and 128-bit encryption. You will also need to have a valid email address on file with PlayBits and have sufficient storage space to save past Communications or an installed printer to print them.

10.3. Withdrawal of Consent. You may withdraw your consent to receive electronic Communications by contacting PlayBits Help Center. If you decline or withdraw consent to receive electronic Communications, PlayBits may suspend or terminate your use of the Services.

10.4. Requesting Paper Copies. If, after you consent to receive Communications electronically, you would like a paper copy of a Communication we previously sent you, you may request a copy within 30 days after the date we provided the Communication to you by contacting PlayBits Help Center. In order for us to send paper copies to you, you must have a current street address on file with PlayBits. Please note that PlayBits operates exclusively online and it is very burdensome for us to produce paper copies of Communications. Therefore, if you request paper copies, you understand and agree that PlayBits may charge you a processing fee, in the amount described in the Fee Structure, for each page of Communication requested.

10.5. Updating Contact Information. It is your responsibility to keep your email address on file with PlayBits up to date so that PlayBits can communicate with you electronically. You understand and agree that if PlayBits sends you an electronic Communication but you do not receive it because your email address on file is incorrect, out of date, blocked by your service provider, or you are otherwise unable to receive electronic Communications, PlayBits will be deemed to have provided the Communication to you. Please note that if you use a spam filter that blocks or re-routes emails from senders not listed in your email address book, you must add PlayBits to your email address book so that you will be able to receive the Communications we send to you. You can update your email address at any time by logging into your PlayBits Account or by contacting PlayBits Help Center. If your email address becomes invalid such that electronic Communications sent to you by PlayBits are returned, PlayBits may deem your account to be inactive, and you may not be able to complete any transaction via our Services until we receive a valid, working email address from you. We shall not be liable for any failure of communication (for any reason).

 

11. Unclaimed or Disputed Property

If for any reason PlayBits is holding Funds in your PlayBits Account, such Funds remain unclaimed, and PlayBits is unable to return your Funds to your designated External Account after a period of three years after your last login to PlayBits or any specified period notified by PlayBits, and PlayBits determines in good faith that it is not able to trace you, you agree that all such Funds shall be deemed to have been abandoned by you in favour of PlayBits and may be appropriated by PlayBits to and for itself, and you thereafter shall have no right to claim such Funds.

If PlayBits receives notice that any Digital Tokens held in your PlayBits Account are alleged to have been stolen or otherwise are not lawfully possessed by you, PlayBits may, but has no obligation to, place an administrative hold on or freeze the affected Digital Tokens or your PlayBits Account. If PlayBits does place an administrative hold on or freeze some or all of your Digital Tokens, PlayBits may continue such hold until such time as the dispute has been resolved and evidence of the resolution acceptable to PlayBits has been provided to PlayBits in a form acceptable to PlayBits. PlayBits will not involve itself in any such dispute or the resolution of the dispute. You agree that PlayBits will have no liability or responsibility for any losses, damages or prejudice arising from or in connection with such hold or freeze, or for your inability to withdraw Digital Tokens or execute trades during the period of any such hold or freeze.

 

12. Acceptable Use

12.1. When accessing or using the Services, you agree that you will not violate any law or any contractual, intellectual property or other third-party right or commit a tort, and that you are solely responsible for your conduct while using our Services. Without limiting the generality of the foregoing, you agree that you will not:

Use our Services in any manner that could interfere with, disrupt, negatively affect or inhibit other users from fully enjoying our Services, or that could damage, disable, overburden or impair the functioning of our Services or bring disrepute

1.The purpose of this Privacy Policy is to inform you and provide you with an understanding of how PlayBIts (“PlayBits” or “we” or “us” or “our”) handles, collects, uses, discloses and deals with personal data about you (“User”) that you give us, that we receive through third parties or that is in our possession. Further, this Privacy Policy governs the manner in which PlayBits collects, uses, maintains and/or discloses personal data collected from Users of the PlayBits.co website (“Site”). To provide you with our Services, we might need (and sometimes obliged by the law) to collect your personal data.

2.We take our responsibilities under the Constitution of Malta and Malta’s Data Protection Act seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.

3.This privacy policy applies to the Site and all Services offered by PlayBits.

Personally identifiable information

4.We may collect personally identifiable information from Users in a variety of ways, including, but not limited to, when Users visit our Site, register on the Site, place an order, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name, email address, mailing address, phone number. Users may, however, visit our Site anonymously. When interacting with us on the Site, Users can always refuse to supply personal data to us, except that it may prevent them from engaging in certain Site related activities or transactions.

Non-personally identifiable information

5.We may collect non-personally identifiable information about Users when they interact with our Site.

What Information Do We Collect?

6.“Personal data” used in this Privacy Policy is to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access. PlayBits collects information about you when you use our websites (including the Site) and other online products and services and throughout other interactions and services you have with us. Personal data which we may collect include:

1. Name

2. Home Address

3. Contact Information

4. Transactional Information

5. Usage and Preferences

6. Identification number

7. Account Number

We will collect your personal data in accordance with the legislative purpose of the DPA.

7.We may also collect and store certain information automatically when you visit the Site. Examples include the internet protocol (IP) address used to connect your computer or device to the internet, connection information such as browser type and version, your operating system and platform, a unique reference number linked to the data you enter on our system, login details, the full URL clickstream to, through and from the Site (including date and time), cookie number and your activity on our Site, including the pages you visited, the searches you made and, if relevant, the products/services you purchased.

8.We may receive information about you from third parties if you use any websites or social media platforms operated by third parties (for example, Facebook, Instagram, Twitter etc.) and, if such functionality is available, you have chosen to link your profile on the Site with your profile on those other websites or social media platforms.

Cookies

9.We may use cookies to identify you from other users on the Site.

10.A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device.

11.You can block or deactivate cookies in your browser settings.

12.We use log-in cookies in order to remember you when you have logged in for a seamless experience.

13.We use session cookies to track your movements from page to page and in order to store your selected inputs so you are not constantly asked for the same information.

14.This Site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the Site and ways that we can improve your experience. These cookies may track things such as how long you spend on the Site and the pages that you visit so we can continue to produce engaging content.

15.By continuing to use the Site, you are agreeing to the use of cookies on the Site as outlined above. However, please note that we have no control over the cookies used by third parties.

16.For further information on types of cookies and how they work visit www.allaboutcookies.org

Purposes For Collection, Use, Disclosure And Processing Of Your Personal Data

17.PlayBits will/may collect, use, disclose and/or process your personal data for one or more of the following purposes:

(a)administering, facilitating, processing and/or dealing in any matters relating to your use or access of the Site, including identifying you for login to the Site, our portals and other online services provided by or on behalf of us;

(b)monitoring, processing and/or tracking your use of the Site in order to provide you with a seamless experience, facilitating or administering your use of the Site, and/or to assist us in improving your experience in using the Site;

(c)assessing and processing your request for the purchase of and/or subscription to our products and/or services;

(d)registering you as a customer of PlayBits and/or to deal with, process and/or administer the account that you may open with us, whether a membership account or otherwise, including to facilitate your transactions or activities on the Site, or your transactions or activities with us;

(e)administering, facilitating, processing and/or dealing with your relationship with us, any transactions or activities carried out by you on the Site or with us. This includes processing your application, orders and payment transactions; implementing transactions and the supply of products and/or services to you that you have requested;

(f)carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf including responding to your enquiries and complaints; or responding to or dealing with your interactions with us;

(g)contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for the purposes of administering and/or managing your use of the Site, your membership and/or account with us, your relationship with us or any transactions made by you with us. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;

(h)providing services to you as our account holder, as our customer, or when requested by you; dealing with or administering your participation in contests, gamification, social events organized by us;

(i)understanding your interests, concerns and preferences;

(j)identifying you and assisting you in your use of our products, services and website services;

(k)for marketing purpose and in this regard, we would be providing you with marketing, advertising and promotional information, materials and/or documents relating to products, contests, services and/or events (including those of third party organisations with which PlayBits may collaborate with) that PlayBits (including its affiliates/related corporations) or such third party organisations may be selling, marketing, offering, organizing, involved in or promoting, whether such products, services and/or events exist now or are created in the future:

(i)by way of postal mail, electronic transmission to your email address(es), and/or through other modes of communication that is not the 3 DNC Modes, in compliance with applicable local data protection law (i.e. the DPA). You may opt out of this or withdraw from this at any time by sending an email to our Data Protection Officer. For the avoidance of doubt, the application of or your acceptance of or your consent to, this Privacy Policy, constitutes your consent to this subparagraph (i);

(ii)if you have separately expressly consented to one or more of the following 3 DNC Modes, by way of the 3 modes of communications of voice calls, text messages or faxes (the “3 DNC Modes”) to your telephone number, in compliance with the requirements of applicable local data protection law (i.e. the DPA); and/or

(iii)Notwithstanding (ii) above, regardless that you have not separately provided express consent as aforementioned in (ii) above, PlayBits reserves its right to send a specified fax message and/or a specified text message (i.e. a marketing fax message or marketing text message) to your telephone number, to which PlayBits reserves the right for final interpretation;

(l)carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations (whether foreign country) applicable to us or our affiliates/associated companies, the requirements or guidelines of governmental authorities (whether foreign country) which we determine are applicable to us or our affiliates/associated companies, and/or our risk management procedures that may be required by law (whether foreign country) or that may have been put in place by us or our affiliates/associated companies;

(m)to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with conflict of interests; or dealing with and/or investigating complaints;

(n)complying with or as required by any applicable law, court order, order of a regulatory body, governmental or regulatory requirements, of any jurisdiction applicable to us or our affiliates/associated companies, including meeting the requirements to make disclosure under the requirements of any law binding on us or our affiliates/associated companies, and/or for the purposes of any guidelines issued by regulatory or other authorities (whether of elsewhere), with which we or our affiliates/associated companies are expected to comply;

(o)complying with or as required by any request or direction of any governmental authority (whether foreign country) which we are expected to comply with; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities (whether foreign country). For the avoidance of doubt, this means that we may/will disclose your personal data to such parties upon their request or direction;

(p)conducting research (including customer research), surveys, market surveys, analysis and/or development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services and facilities, or to improve our understanding of your interests, concerns and preferences, in order to enhance any continued interaction between yourself and us connected or in relation to the Site, or improve any of our products or services;

(q)storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside

(r)facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of PlayBits or that of its affiliates/related corporations;

(s)to create reports with respect to our transactions with you, and/or producing statistics and research of such transactions for internal and/or statutory reporting and/or record-keeping requirements;

(t)dealing with and/or facilitating a business asset transaction or a potential business asset transaction, where such transaction involves PlayBits as a participant or involves only a related corporation or affiliated company of PlayBits as a participant or involves PlayBits and/or any one or more of PlayBits’s related corporations or affiliated companies as participant(s), and there may be other third party organisations who are participants in such transaction. “business asset transaction” means the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation;

(u)anonymization of your personal data. In this regard, you acknowledge that personal data that has been anonymized is no longer personal data and the requirements of applicable local data protection law (i.e. the DPA) would no longer apply to such anonymized data;

(v)PlayBits, PlayBits Group Companies’ reporting purposes including but not limited to reporting on PlayBits’s business performance (“PlayBits Group Companies” means PlayBits, its affiliates, related corporations and associated companies globally); including producing statistics and research for internal and/or statutory reporting and/or record-keeping requirements, of PlayBits or of its affiliates/related corporations; and/or

(the purposes set out above shall be collectively referred to as the “Purposes”).

18.PlayBits may/will need to disclose your personal data to third parties, whether located within, for one or more of the above Purposes, as such third parties, would be processing your personal data for one or more of the above Purposes. In this regard, you hereby acknowledge, agree and consent that we may/are permitted to disclose your personal data to such third parties (whether located within) for one or more of the above Purposes and for the said third parties to subsequently collect, use, disclose and/or process your personal data for one or more of the above Purposes. Without limiting the generality of the foregoing or of paragraph 17, such third parties include:

(a)our associated or affiliated organisations or related corporations;

(b)any of our agents, contractors or third party service providers that process or will be processing your personal data on our behalf including but not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies and data centres; and

(c)third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.

19.You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by emailing us at [email protected] We will process your request [within a reasonable time] from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request, unless an exception under the law or a provision in the law permits us to. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal, including us being unable to perform the transactions requested by you in the Site.

20.We may collect, use, disclose or process your personal data for other purposes that do not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the DPA or by law.

21.We may/will also be collecting from sources other than yourself, personal data about you, for one or more of the above Purposes, and thereafter using, disclosing and/or processing such personal data for one or more of the above Purposes. We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the Purposes set out above (depending on the types of information we receive).

How we protect your personal data

22.We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal data, username, password, transaction information and data stored on our Site.

23.Sensitive and private data exchange between the Site and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures. Our Site is functioning in compliance with PCI vulnerability standards in order to create as secure of an environment as possible for Users.

24.We will put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.

Sharing your personal information

25.We do not sell, trade, or rent Users’ personally identifiable information to others. We may share generic aggregated demographic information not linked to any personally identifiable information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.

Rights

26.You have the right to ask us not to use your personal data for marketing purposes. Please let us know if you want to withdraw your consent by emailing us at [email protected]

27.You have the right to access and/or correct any personal data that we hold about you, subject to exceptions under the law. This right can be exercised at any time by emailing us at [email protected] We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. With respect to your access request, we may charge a fee in order to process it.

28.For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested.

29.For a request to correct personal data, once we have sufficient information from you to deal with the request, we will correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. We will send the corrected personal data to every other organization to which the personal data was disclosed by us within a year before the date the correction was made, unless that other organization does not need the corrected personal data for any legal or business purpose.

30.We hold and deal with your data in accordance with the DPA.

Complaint Process

31.If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the DPA (when in force), we welcome you to contact us with your complaint or grievance.

32.Please contact us with your complaint or grievance by emailing us at [email protected]

33.Where you are sending an email in which you are submitting a complaint, your indication at the subject header that it is a DPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organization to handle. For example, you could insert the subject header as “DPA Complaint”.

34.We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.

Changes to this privacy policy

35.PlayBits has the discretion to update this privacy policy at any time. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Your acceptance of these terms

36.By using this Site, you signify your acceptance of this policy and Terms of Use. If you do not agree to this policy, please do not use our Site.

General

37.Your consent that is given pursuant to this Privacy Policy is additional to and does not supercede any other consents that you had provided to PlayBits with regard to processing of your personal data.

38.For the avoidance of doubt, in the event that data protection law permits an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply.

If you have any queries on this Privacy Policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer at [email protected]

The PlayBits AML Policy is designed to prevent money laundering, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:

The appointment of a Money Laundering Reporting Officer (MLRO) who has sufficient level of seniority and independence and who has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance;

●     Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company;

●     Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs);

●     Establishing and maintaining risk based systems and procedures to monitor on-going customer activity;

●     Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;

●     The maintenance of appropriate records for the minimum prescribed periods;

●     Training and awareness for all relevant employees

Counter Financing of Terrorism (CFT)

The Company takes a risk-based approach when adopting and implementing counter financing of terrorism (CFT) measures and in conducting AML risk assessments.

The company adopted internal CFT controls and make undefended decisions regarding CFT matters supersedes any business, strategic or other operating task.

International Sanctions Policy (ISP)

Our company is prohibited from transacting with individuals, companies and countries that are on prescribed sanctions lists.

Know Your Customer Procedures (KYC)

Individuals can be identified by passport or other identification document and utility bills stating their current post address. Companies have to be identified by extracts from the Chamber of Commerce or by notary deed. Copies have to be made and archived in files securely.