We are committed to protecting your privacy and take the protection of your personal data very seriously. This privacy policy (“Privacy Policy”) explains how we collect, use and share the personal data that you provide to us and what we collect when you use any of our websites (each, a “Website”) information submission, contact services, messaging services, virtual assets, polls, surveys, and similar services (each, a “Site Feature”). The Website and Site Features are collectively referred to as the “Services.”

If you are located in the European Union (“EU”) or the UK, this Privacy Policy also informs you about the management of your personal data and your rights in accordance with Article 13 of the General Data Protection Regulation (“GDPR”).

Data Controller

AXES, a Nevada Limited Liability Company with an office in Las Vegas, Nevada, U.S.A., is the entity responsible for determining the means and purposes of processing personal data (i.e., the data controller) under this Privacy Policy and can be contacted as explained below in the How To Contact Us section. AXES has appointed a Data Protection Officer for issues related to personal data in the EU and UK, who can be contacted at.

Changes to the Privacy Policy

We ask that you read this Privacy Policy from time to time. We may modify it at any time in our sole discretion. If we make material changes to this Privacy Policy that increase our rights to use personal data that we have previously collected about you, we will obtain your consent, where required by law, either through your registered email address or by prominent posting on the Services. Where permitted by law, your use of the Services indicates that you accept the terms of this Privacy Policy.

Personal Data We Collect About You: When you submit information through our Services, AXES may collect the following types of personal data and information relevant to your needs and interests:

Personal data you give us: You may give us personal data in a number of ways, including when you communicate with us using our Services. However, you can use some aspects of the Services at any time without providing any personal data. While providing personal data is voluntary, you may not be able to take advantage of or participate in some of the Services, if you choose not to share it.

Personal data we get from outside sources: We also may collect personal data about you (such as name, address, device IDs, location, Internet service provider, and usage and player information) from third parties, such as advertisers, platforms, analytics companies, vendors, and fraud detection companies. We use this data to improve the quality and relevance of the information you see, improve the functionality of the Services or let you know of new developments in the Services. In the event that we receive such data and combine it with our customer records, the combined information will be treated in accordance with this Privacy Policy.

Personal data we collect automatically: We may automatically collect information about the devices that you use to interact with the Services, as well as information about how you interact with the Services. The information that we may automatically collect could include the following, depending on which Service you are using:

· Your IP Address;

· Device identifier;

· Web browser type and version;

· Operating system;

· Time zone;

· Web browsing;

· Location based upon IP Address;

· Precise geolocation of mobile device;

· Page/app views; and

· Language.

How We Protect Children’s Privacy

Our Services are provided to a general audience and not directed to children under the age of 18. If we obtain actual knowledge that any information we collect has been provided by an individual under the age of 18, we will promptly delete that information.

If you are a parent or guardian who has discovered that your child has submitted his or her personal data to AXES, please send an email to to request deletion of that information.

How We Use Personal Data We Collect About You

We use your personal data for the following purposes:

Communicate With You

· To respond to your inquiries and provide you with customer support;

· To communicate with you about our products and services;

· To make suggestions and recommendations to you about goods or services that may interest you; and

· To let you know about new developments in the Services.

· To improve your experience using the Services;

· To improve the functionality of the Services;

· For internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

· To measure or understand the effectiveness of advertising we serve to you and others;

· To deliver relevant information to you; and

· To assist us in developing new products and improving our Services.

Ensure a Secure Online Environment and Comply with Legal Obligations

· Protect against and detect fraud, abuse or other unlawful activity;

· Enforce our policies and industry standards; and

· Comply with all applicable laws and reporting obligations.

Unsubscribing From Communications: AXES may use your personal data to communicate with you directly via email, push notifications or direct mail, about products and services we believe may be of interest to you, as well as related customer support. If you no longer want to be contacted, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or by contacting us.

When We Share Your Personal Data To Support Business Services: We may share your personal data with companies who perform services on our behalf to support our business operations, including the following:

· Product and/or experience customization;

· Distribution of marketing and promotional material;

· Website and Services evaluation;

· Data collection, storage, management, analysis and, where applicable, deletion; and

· Other services to support our business operations, such as ad delivery and analysis.

To Provide Company Security: We disclose personal data when we determine that doing so is appropriate to:

· Verify compliance with and enforce our policies governing our Services;

· Protect our property, services and legal rights;

· Protect personal safety or the property of others;

· Respond to lawful requests from governmental authorities;

· Comply with applicable laws; and

· Support auditing, compliance and corporate governance functions.

In the Event of Corporate Change: We disclose, sell or transfer information related to the Services, including personal data: · To a subsequent owner, co-owner or operator of one or more of the Services; or · In connection with a corporate merger, consolidation or restructuring; the sale of substantially all of our stock and/or assets; or other corporate change, including, without limitation, during the course of any due diligence process. You may, in our sole discretion, be notified by e-mail or notice on our Website in the event of a change of ownership or control of your personal data.

For Statistical Analysis: We may disclose non-identifying, aggregated user statistics, such as the number of users who used the Services during a specific time period, to third parties for a variety of purposes, including describing our Services to prospective partners and other third parties.

Cookie Policy

Our Services do not currently use cookies. In the future, use of our Services, including visiting our Website, may place small data files on your computer or mobile device. These data files may be cookies, pixel tags, e-tags, or other local storage provided by your browser or Apps (collectively “Cookies”). Some of these Cookies may be technical (i.e., they would allow us to provide the Services) and some may be non-technical (i.e., they would provide analytics about the use of our Services, allow us to remember your preferences, or facilitate advertising and other features). We may also use third-party advertisers (each, a “Third-Party Advertiser”) to market, sell and display advertisements on our Services. These Third- Party Advertisers may recognize Cookies we have placed (or place their own Cookie) on your device to collect information about your use of the Services for use in connection with their advertising activities. There are persistent and session Cookies. Persistent Cookies are used to improve your experience. This includes, for example, recording your acceptance of our Cookie Policy to remove the Cookie message that first appears when you use our Services. Session Cookies are temporary and are deleted from your device when your web browser closes. Session Cookies can be used to help track internet usage. We may in the future use both persistent and session Cookies. If we do use Cookies in the future, then we will not keep the personal data that we collect through Cookies for longer than is necessary to fulfill the purposes mentioned in this Privacy Policy.

Web Beacons

Our Website pages or e-mail messages may contain a small graphic image called a web beacon, which allows us to monitor and collect certain limited information about our users, such as the type of browser requesting the web beacon, the IP address of the computer that the web beacon is sent to and the time the web beacon was viewed. We use web beacons to count visitors to our web pages or to monitor how our users navigate our Services, and we include web beacons in e-mail messages in order to count how many of the messages we sent were actually opened or acted upon.

IP Addresses

An IP Address is a number that is assigned to your mobile device, computer or network when you are linked to the Internet. When you use our Services, our servers log your

IP Address. We may use IP Addresses for a number of purposes, such as system administration, to report aggregate information to our business partners or to audit the use of the Services. We would associate your IP address with other personal data you Provide.


Web analytics services that collect and analyze AXES users’ data, such as device ID and IP address, may be used to provide us with statistical information, such as where our users are located in the world. We use this information to improve and personalize our Services.

How We Protect Your Personal Data

AXES has implemented an information security program that includes safeguards designed to protect personal data.

Data Retention

AXES will retain your personal data as needed to provide you with access to our Services and/or for as long as is necessary for the protection and pursuit of our legal rights and obligations under any laws that are applicable to our operations.

Links to Other Websites

The Services may contain links to other websites. Other websites may also reference, advertise, or link to AXES. AXES is not responsible for the privacy practices or the content of such other websites. You should check the applicable privacy policy of any website you access through the Services.

Location and Transfer of Personal Data

Personal data you provide to us and through our Services may be stored on servers, databases and with service providers in the United States and other countries whose data protection laws may differ from the jurisdiction in which you live. When we transfer personal information from the European Economic Area (“EEA”) or the UK, we put in place appropriate safeguards to ensure the safe and secure transfer and handling of such data.

Do Not Track Signals

Some browsers send signals or preferences to websites that you visit indicating that you do not wish to be tracked over time and across websites. Because there is not yet a common understanding of how to interpret Do Not Track (“DNT”) signals or a common definition of “tracking,” we do not currently respond to DNT signals on our Websites.

Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to opt out of the disclosure of your personal data by AXES to third parties for those third parties’ direct marketing purposes. To make a request to opt out of such disclosure, please contact us through the Website. The California Consumer Privacy Act (“CCPA”) also provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to access and control Personal Information. The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a federal privacy law. To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.

Right to Information Regarding the Categories of Personal Information Collected, Sold, and Disclosed

Please see our Notice of California Consumer Data Collection and Sharing Practices included in our Privacy Policy.

Right to Access Information

You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. To protect our customers’ Personal Information, we will verify your identity before we can act on your request by seeking information which may include: (i) device ID; (ii) your identification; (iii) name; (iv) confirmation of California residency; (v) physical address and/or (vi) Email.

Right to Request Deletion of Information

You have the right to request, in certain circumstances, that we delete any Personal Information that we have collected directly from you. To protect our customers’ Personal Information, we will verify your identity before we can act on your request by seeking information which may include: (i) device ID; (ii) your identification; (iii) name; (iv) confirmation of California residency; (v) physical address and/or (vi) email. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Right to Opt out of Sale of Personal Information to Third Parties

You have the right to opt out of any sale of your personal information to third parties. To exercise this right, please contact us through the Website. Please note that your right to opt out does not apply to our sharing of personal information with any service providers who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal information only for that function.

Right to Non-Discrimination You have the right to receive non-discriminatory treatment based on your exercise of any of the privacy rights conferred by the CCPA.

How to Submit a Request

You may submit a request by contacting us at or through the Website.

Notice to Residents of the EU and the UK

If you are located in the EU or the UK, you have certain rights with respect to your personal data. If you would like to exercise those rights, please contact us at or through the Website.

Legal Basis for Processing

We will rely on the following legal bases for processing your personal data, depending on our purpose for such processing.

You have consented to the processing of your personal data: You have sent a communication to us through our Website.

We have a legitimate interest in processing your personal data: AXES has a legitimate interest in processing your personal data for certain business and security purposes and to comply with applicable laws, including, but not limited to, the following:

· Product and Service development, management, delivery and enhancement;

· Fraud detection and prevention;

· Network and system security;

· General corporate operations;

· User personalization;

· Compliance with applicable foreign laws;

· Communications regarding your inquiries and interests; and

· Non-targeted marketing and advertising.

You have the right to object to our processing of your personal data based on our legitimate interests. You can do so by contacting us through the Website as described above. The processing of some types of personal data is necessary to provide the Services. Therefore, if you object to certain types of processing, we may not be able to provide you with the Services.

Processing is necessary for compliance with a legal obligation: We will process personal data when necessary to comply with an obligation under EU or EU Member State law. If we intend to use personal data that we have collected for a different purpose than was described to you, we will provide you with information about this secondary purpose and any additional information necessary to ensure fair and transparent processing, before we engage in further processing.

Rights of Individuals Located in the EU or UK: If you are located in the EU and UK, you have the following rights, subject to applicable exceptions, under the GDPR and UK data protection laws:

Right of access: You have the right to obtain confirmation as to whether we are processing personal data about you, and if so, request a copy of the personal data. If you are located in the EU or UK and you would like a copy of the personal data that AXES holds about you, please send a description of the personal data you would like a copy of and proof of your identity to the emails set forth above.

Right to correction: You have the right to correct any inaccuracies in the personal data we hold about you and, where applicable, complete any incomplete personal data that we hold.

Right to erasure: You have the right to request that AXES erase the personal data that we hold about you, if one of the conditions in Article 17 of the GDPR applies.

Right to restriction of processing: You have the right to restrict our processing of your personal data, if one of the conditions in Article 18 of the GDPR applies.

Right to data portability: You have the right to receive personal data concerning you in a structured, common and machine-readable format or request transmission of the data to a third party, if the conditions in Article 20 of the GDPR are met.

Right to object: You have the right to object to processing of your personal data based on our legitimate interests at any time. We will no longer process the data, unless there are compelling legitimate grounds for our processing that override the interests, rights and freedoms of the data subject, or the processing serves the purpose of asserting, exercising or defending legal claims.

Right to withdraw consent: If we are processing your personal data based on your consent, you have the right to withdraw your consent at any time. If you are located in the EU or UK and you would like to invoke any of these rights (other than “access,” which is explained above), you can make the appropriate change through your AXES Account, or you can contact us as described above.

Lodging a Complaint: Under Article 77 of the GDPR, if you are located in the EU or the UK, you have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal data infringes your rights under the GDPR. The right to lodge a complaint may be invoked in the EU Member State in which you reside, in which you work or where the alleged infringement occurred.

How You Can Contact Us

AXES is dedicated to protecting your personal data and welcomes comments and questions on this Privacy Policy. You may e-mail us at the following address:

Notice of California Consumer Data Collection and Sharing Practices

The following is a description of our data collection practices, including the personal information we collect, the sources of that information, the purposes for which we collect information, and whether we disclose that information to external parties. We may use any and all of the information for any of the purposes described in our Privacy Policy, unless limitations are listed. The categories we use to describe the information are those enumerated in the CCPA.

Personal Identifiers:

We collect information such as your name, email address, phone number, and contact address when you submit a communication to us through our Website.

We do not collect your Driver’s License or passport number.

We do not collect any medical information or health information about you.

We do no collect your social security number.

We may collect your IP address automatically when you use our Services.

We may collect your Device ID automatically when you use our Services.

· Protected Classifications: We may collect your age in order to comply with laws that restrict collection and disclosure of personal information belonging to minors. We do not collect your racial or ethnic origin, or sexual orientation.

· Biometric Information: We do not collect information about your physiological, biological, or behavioral characteristics.

· Internet or Other Electronic Network Activity Information: We may collect information about your browsing history, search history, and information regarding your interaction with websites, applications, or advertisements automatically when you utilize our Services.

· Geolocation Data: As described above, we may collect your IP address automatically when you use our Services. We may be able to determine your general location based on the IP address. We do not collect your precise location (e.g., your GPS coordinates).

· Audio, electronic, visual, thermal, olfactory, or similar information: We do not collect your image, voice recording, or any thermal, olfactory, or similar information.

· Professional or employment-related information: We do not collect information about your current employer or your employment history.

· Education information: We do not collect any information about the institutions you have attended or the level of education you have attained.

· Other Third Party Disclosure: We may also disclose information to other external parties who are not listed here when required by law or to protect AXES or other persons, as described in our Privacy Policy.