This Privacy Policy is incorporated and made a part of NGMGame terms of service.

1.This Privacy Policy (hereinafter referred to as the "Policy") sets forth the general rules of collection, processing, distribution, use and storage of Website user's Personal data including any dispute concerning privacy under current General Data Protection Regulation (GDPR), and in accordance with the data protection regulations in Curaçao applicable to Ludos Optima N.V., a company incorporated at Zuikertuintjeweg Z/N (Zuikertuin Tower), Willemstad, Curacao (hereinafter the "NGMGame", "Company", "Us", "We").

2.It is understood and presumed that by the fact of use of the Website and its services or by clicking "I'm at least 18 years old and accept Terms of use and Privacy policy" button the User gives Consent, that he/she/it has fully read, understood and accepted this Policy. If any User does not agree with this Policy in general or any part of it, such User should withhold from using the Website and its services.

3.The following definitions and rules of interpretation apply in this Privacy policy:

For the purposes of this Regulation:

• 'Personal data' means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

• 'Processing' means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

• 'Restriction of processing' means the marking of stored personal data with the aim of limiting their processing in the future;

• 'Profiling' means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

• 'Pseudonymisation' means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;

• 'Controller' means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

• 'Processor' means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

• 'Recipient' means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

• 'Third party' means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

• 'Consent' of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

• 'Personal data breach' means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;

• 'Genetic data' means personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question;

• 'Biometric data' means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data;

• 'Data concerning health' means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;

• 'Website' means a group of interrelated websites owned and operated by Ludos Optima N.V.;

• 'Cookie' is a text file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. For more information on managing cookies, please go to www.allaboutcookies.org, or visit www.youronlinechoices.com.

• 'Sensitive personal information' An information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person's sex life or sexual orientation.

4.This Privacy Policy may be modified, changed, supplemented, updated at any time with prior written notice from NGMGame. Your continued use of the Website and its services after any amendments or alterations of this Privacy Policy without notification of NGMGame shall constitute your consent hereto and acceptance hereof of an updated version of this Privacy Policy. At any case, the date of the most recent amendments and alterations will be indicated at the top of this web page. If the User does not agree to such revised terms of the Privacy Policy or Terms of Use he/she must stop using this Website and may withdraw from his/her obligations under this Privacy Policy.

5.The data controller of this Website is Ludos Optima N.V., a company incorporated at Zuikertuintjeweg Z/N (Zuikertuin Tower), Willemstad, Curacao. Contact details: dpo.NGMGame.com@gmail.com

6.The data processor of this Website is Ludos Optima N.V., a company incorporated at Zuikertuintjeweg Z/N (Zuikertuin Tower), Willemstad, Curacao, dpo.NGMGame.com@gmail.com

7.The Data Protection Officer is: Ludos Optima N.V., a company incorporated at Zuikertuintjeweg Z/N (Zuikertuin Tower), Willemstad, Curacao,dpo.NGMGame.com@gmail.com

Any authorized person or regulatory body may, at any time, contact Data Protection Officer directly with any request related to data protection.

8.All personal data of data subject is processed in compliance with Art. 6(1) of GDPR and in pursuance of the controller's obligation to receive consent of data subject for specific processing operations with personal data.

9.The Website of the Ludos Optima N.V. collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files.

10.The following information may be collected for general purposes:

10.1.the browser type and its version;

10.2.the operating system used by the accessing system;

10.3.the website from which an accessing system reaches the website;

10.4.the sub-websites;

10.5.the date and time of access to the Internet site;

10.6.an Internet protocol address (IP address);

10.7.the Internet service provider of the accessing system;

10.8.any other similar data and information that may be used in the event of attacks on our information technology systems.

11.When using these general data and information, Ludos Optima N.V. does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Ludos Optima N.V. analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

12.The following information can be collected for services purposes:

12.1.Contact information, such as name, home address, and email address;

12.2.Account information, such as username (first name, last name, nickname), gender and password;

12.3.Information related to your virtual wallets public addresses;

12.4.Financial information, such as bank account numbers, bank statement, and trading information;

12.5.Identity verification information, such as images of your government issued ID, passport, national ID card, or driving license;

12.6.Residence verification information, such as Utility bill details (city, country) or similar information.

13.Processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation are prohibited.

Such rule will not apply if one of the following applies:

• The data subject has given explicit consent to the processing of those personal data for one or more specified purposes, except where Union or Member State law provide that the prohibition may not be lifted by the data subject;

• Processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject;

• Processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;

• Processing is carried out in the course of its legitimate activities with appropriate safeguards by a foundation, association or any other not-for-profit body with a political, philosophical, religious or trade union aim and on condition that the processing relates solely to the members or to former members of the body or to persons who have regular contact with it in connection with its purposes and that the personal data are not disclosed outside that body without the consent of the data subjects;

• Processing relates to personal data which are manifestly made public by the data subject;

• Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity;

• Processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject;

• Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional;

• Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of Union or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject, in particular professional secrecy;

• Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

14. You agree that We may, from time to time, use a cookie on your device to save information (such as Customer name, password, other personal details, e-mail address etc.) so you do not have to re-enter this information each time you visit our site. This cookie cannot be used to run programs or deliver viruses to your computer, and is uniquely assigned to you. It can only be read by a web server in the domain that issued the cookie to You.

15. The primary purpose of the cookie is to enable you to save time and facilitate future access to the site. We do not use cookies that are intrusive to your privacy (tracking cookies) for the purpose of capturing online promotional behaviour (behavioural marketing). In the event that this type of cookie is employed, we will ask for your consent.

16.Communication and Opt-out

In registering an account to use our service, you consent to us contacting you through any and all means of communication (whether in written or verbal form and including, but not limited to e-mail, telephone and SMS) in respect of matters relating to your account.

To unsubscribe from any or all forms of communication, please either use the 'Unsubscribe' link found in our promotional e-mails or contact us at website/email.

17.Refusing Cookies

We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place. You can limit the collection of your information by disabling cookies on your browser. You may also be able to modify your browser settings to require your permission each time a site attempts to set a cookie. However, our website(s) (and many other websites) rely on cookies to enable certain functionality. If you choose to disable cookies, some of the services available on our website may not work properly.

18.Non-NGMGame Websites and Links

Our websites may contain links to non- NGMGame websites. We are not responsible for the practices of those third party websites. Where you access other websites from our sites using the links provided, the operators of these websites may use cookies in accordance with their own cookies policy, which may differ from ours. You should read their privacy and cookie policies carefully before you provide any personal information to them.

19.The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject is collected and stored for internal use by the controller. The controller may request transfer of the data to one or more processors or partners that also uses personal data for an internal purpose which is attributable to the controller.

20. By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

21. The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.

22. On the website of the Ludos Optima N.V., users are given the opportunity to subscribe to newsletter service. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller. The newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter. During the registration for the newsletter, a Website also store an IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The personal data collected as part of a registration for the newsletter will only be used to send our newsletter.

23. The website contains information that enables a quick electronic contact to Ludos Optima N.V. If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject is automatically