PRIVACY AND COOKIES POLICY

GDC Media Limited, a subsidiary of Grandstand Limited (Nasdaq: GRSD) (“GRSD”).

The terms “Grandstand”, “we”, “us”, or “our” refer collectively to GRSD, and its current and future subsidiaries (“Group Members”).

GDC Media Limited is the owner of the websites, including without limitation associated social media accounts, and mobile applications (collectively, “websites”) operated by and on behalf of Grandstand except for certain Grandstand websites which are owned by Rollcard, LLC, another Group Member.

GDC Media Limited has licensed the operation of certain Grandstand websites operating in the United States to GDC America, Inc.

This Privacy and Cookies Policy (“Policy”) describes the practices of GDC Media Limited, Rollcard, LLC and the Group Members involved in the operation of the Grandstand’s websites in different geographic locations and the rights and choices available to individuals regarding personal data.

Please note, Rollcard, LLC operates as a program manager and service provider for the Rollcard services, including those offered through Rollcard’s websites, customer support interactions, and related services in the United States. Banking services that are part of the Rollcard services, including consumer deposit accounts and debit cards, are provided by Rollcard’s sponsor bank, Cross River Bank, a commercial bank chartered in New Jersey, United States of America. Both Rollcard and the sponsor bank may collect, process, and retain Personal Data, including non-public personal information (as that term is defined by the Gramm-Leach-Bliley Act) in connection with the Rollcard services. This Policy does not govern Rollcard’s handling of such non-public personal information. For information about Rollcard and Cross River Bank’s practices with respect to such non-public personal information, please visit Rollcard’s Consumer Privacy Notice and Cross River Bank’s Consumer Privacy Notice.

1. PURPOSE OF THIS POLICY

Grandstand respects your privacy and is committed to protecting your personal data. Personal data means any information that relates to an identified or identifiable individual. It does not include data where the ability to identify an individual has been removed (anonymous data).

This Policy describes how Grandstand collects, uses, discloses, and maintains Personal Data, as well as your rights and choices regarding your personal data. It is important that you read the Policy carefully. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact us as set out below.

We may alter this Policy at any time and from time to time as needed for certain services of Grandstand and to abide by local laws or regulations around the world, including by providing supplemental information to users in certain jurisdictions. This Policy does not apply to Grandstand’s processing of the personal data of its personnel, such as employees and contractors.

We also provide important additional information, which users should read,  that is solely applicable to individuals located (i) within the Member States of the European Union, countries in the European Economic Area, the United Kingdom, and Switzerland (collectively, “Europe” or “European”), (ii) in Brazil, and (iii) in California, Colorado, Connecticut, Delaware, Montana, Nevada, Utah, Iowa, Florida, Washington, Virginia and other states of the United States, (iv) in Australia, (v) in Canada and (vi) in Mexico.

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect, use or otherwise handle data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave any of our websites, we encourage you to read the privacy policy of every website you visit.

2. THE PERSONAL DATA WE COLLECT

We collect personal data about individuals from various sources described below. Where applicable, we will let you know how we intend to use your data before collecting it, so that you can decide whether or not you wish to provide that information. We may collect, use, store and transfer different kinds of personal data about you (“Personal Data”) which we have grouped as follows:

“Personal Information” includes any information from which (alone or when used in combination with other information) you can be personally identified, including your name, surname, email address, telephone number or mobile number. The Personal Information we collect varies depending on our relationship and interactions with you.

Personal Information, sometimes referred to as “personal data”, may also have specific meanings under different privacy laws.

“Profile Data” includes a username (or nickname), password (encrypted), login and logout times and a profile image that an individual may establish and upload on one of our websites or mobile applications, along with any comment or content posted by that user and any other information that an individual enters into their account profile (e.g. ‘Freemium’ account);

“Financial Account Data” includes payment card details or bank account details;

“Recruitment Process Data” includes the CV and any covering letter of a job applicant and notes taken for the duration of your recruitment process relating to a job application and interview of a job applicant, and other information supplied by a job applicant, such as professional credentials and skills, educational and work history, and other information of the type included on a CV or covering letter;

“Usage Data” includes information about how you use our websites. This Usage Data may include information such as your computer's or other device’s Internet Protocol address (e.g. IP address), browser type, browser version, operating system and platform, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access our mobile applications with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our services, to improve and customize our services.

You can enable or disable location services when you use our services at any time by way of your device settings.

We also may collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

We may retain recordings of any telephone voice messages that you have left for our customer support teams.

We automatically collect Usage Data. If you are using a mobile device, we collect data that identifies your mobile device, device-specific settings and characteristics, app crashes and other system activity.

“Rollcard Data” includes information necessary to provide Rollcard, LLC’s services, comply with legal and regulatory requirements, and protect customers and the financial system. This may include information such as your name, date of birth, government-issued identification numbers, contact information, financial account and routing numbers, transaction history, funding source information, account balances and activity, identity verification data, KYC information, AML and fraud monitoring data, device identifiers, IP addresses, log and usage data, and application interaction data. To the extent this information is considered non-public personal information, as defined by the Gramm-Leach-Bliley Act, it is subject to Rollcard, LLC’s Consumer Privacy Notice, not this Policy.

We do not collect any information about your race, ethnicity, religious or philosophicalbeliefs, gender or sexual orientation, political opinions, trade union membership,information about your health, and genetic and biometric data. However, if you are applyingfor a job with us, we will collect information about criminal convictions and offences.

3. COLLECTION OF PERSONAL DATA

We may use different methods to collect data from and about you including the following:

• Direct interactions. You may give us your Personal Information, Profile Data, FinancialAccount Data and Recruitment Process Data by: a) filling in a job application form onour Career Page, b) providing an email address to register with our websites and/orreceive our newsletter, c) posting comments during your use of our sites, and/or d)providing your contact details, payment card details and/or account log-in details viaour registration and/or newsletters form.
• Indirect interactions. You may give us your Personal Information indirectly byproviding an email address and/or contact details to register with websites of and/orreceive newsletters or other forms of communication from entities with whom wehave an agreement to work in partnership with and provide services to (“Media Partners”).
• Automated technologies. As you interact with our websites, we will automaticallycollect Usage Data about your equipment, browsing actions and patterns. We collectthis data by using cookies, pixels, server logs and other similar technologies, thirdparties or publicly available sources. We may partner with third parties (such ascontent providers, advertising platforms, and analytics companies including Google(via Google Analytics GA4 and Google Ads), Meta (via the Meta Pixel and MetaConversions API), Microsoft (via the UET Tag and Bing Ads), TikTok, Snapchat,Pinterest, Reddit, X (formerly Twitter), Everflow, OptInMonster, Hotjar, customer.io,segment.io, Mixpanel and Convert.com, to help us improve the services of ourwebsite, including to provide you with relevant and interesting content, to conductanalytics and measurement to understand how our services are used, and to deliver, measure and optimize advertising. These companies may collect information fromyou automatically in connection with your visit, including through the use of cookies,pixels, and similar tracking technologies, as well as through server-side dataintegrations (such as the Meta Conversions API). We may use third-party serviceproviders to automate the development process of our service (such as developmentplatform to host and review code, manage projects, and build software , includingGitHub).

Generally, our websites can be accessed and used without registration and without havingto provide us any Personal Data (Personal Information, Profile Data, and/or RecruitmentProcess Data). You may opt in to receive information about promotions, bonuses, bets, tipsand strategy by subscribing to one or more of our mailing lists by providing your emailaddress. You may any time opt out from receiving such communications by writing to us orclicking the “unsubscribe” button in any of our emails to you. In case you contact us,whether by email, through contact forms, or in other writings, we may keep a copy of thatcorrespondence. We will not share your Personal Data with third parties for marketingpurposes unless you have provided us with your express consent to do so and/or, withrespect to our Media Partners, you have consented to receive marketing communicationsfrom those Media Partners. You may withdraw your consent by contacting those MediaPartners directly. You may not withdraw your consent given to our Media Partners bycontacting the Group Members.

4. USE OF PERSONAL DATA

We may use your Personal Data for the purposes of:

Providing our services, which may include:

• Operating, evaluating, maintaining, improving, and providing the features and functionality of our services;
• Notifying you about changes to our services;
• Fulfilling a payment transaction initiated by you;
• Communicating with you regarding your account with us (if you have one), includingby sending you service-related emails or messages (e.g., messages regarding accountverification, changes or updates to the functionality of our services, technical andsecurity notices and alerts, notices about your subscription, including expiration andrenewal notices, email-instructions, and support messages)
• Personalizing the manner in which we provide our services;
• Administering and protecting our business;
• Provide you with news, special offers and general information about other goods,services and events which we offer that are similar to those that you have alreadypurchased or enquired about unless you have opted not to receive such information;
• Monitoring the usage of our services;
• Detecting, preventing and addressing technical issues; and
• Providing support and maintenance for our services, including responding to your service-related requests, questions, and feedback.

For research and development

We use the information we collect for our own research and development purposes, which include:

• Developing or improving our services; and
• Developing and creating analytics and related reporting.

Marketing

We may use your Personal Data to form a view on what services we think you may want or need or what may be of interest to you.

We may contact you with marketing communications using the Personal Data you have provided to us if you have actively expressed your interest in availing of our services or haveavailed of our services and, in any case, you have not opted out of receiving that marketing,to the extent permitted by applicable law.

You can ask us to stop sending you marketing messages at any time by contacting us using the details below or clicking on the opt-out link included in each marketing message.

Should you choose to opt out of receiving our marketing messages, we will continue to conduct our other relevant activities using your Personal Data, including sending non-marketing messages.

Managing our recruiting and processing employment applications

We process Personal Data, such as information submitted to us in a job application, tofacilitate our recruitment activities and process employment applications, such as byevaluating a job candidate for an employment activity, and monitoring recruitmentstatistics.

Complying with law

We use your Personal Data as we believe necessary and appropriate to comply withapplicable laws, lawful requests and legal process, such as to respond to subpoenas orrequests from government authorities.

Compliance, fraud prevention and safety

We use your Personal Data as we believe necessary or appropriate to (a) enforce the termsand conditions that govern our services; (b) protect our rights, privacy, safety or property,and/or that of you or others; and (c) protect, investigate and deter against fraudulent,harmful, unauthorized, unethical or illegal activity.

With your consent

In some jurisdictions, applicable law may require us to request your consent to use yourPersonal Data in certain contexts, such as when we would like to send you certain marketingmessages. If we request your consent to use your Personal Data, you have the right towithdraw your consent any time in the manner indicated when we requested the consentor by contacting us. If you have consented to receive marketing communications from ourthird-party partners, including our Media Partners, you may withdraw your consent bycontacting those partners directly (and not by contacting us).

To create anonymous data

We may create anonymous data from your Personal Data and other individuals whosePersonal Data we collect. We make Personal Data into anonymous data by excludinginformation that makes the data personally identifiable to you and use that anonymousdata for our lawful business purposes.

For Rollcard Services

In addition to the above-described uses of your Personal Data, when you interact withRollcard, LLC, we may use your Personal Data to communicate with you, provide customersupport, and, where applicable, to meet regulatory requirements. Please note that, withrespect to former Rollcard customers who have closed their Rollcard accounts, we mayretain and disclose information about them as described in this Policy, consistent withapplicable legal and regulatory requirements.

5. TO WHOM DO WE PROVIDE PERSONAL DATA

We may have to share your data to the following parties:

Group Members

We may disclose your Personal Data to other Group Members for purposes consistent with this Policy.

Service providers

We may employ third parties to administer and provide services on our behalf (such as thirdparties that provide customer support, that we engage to host, manage, maintain, anddevelop our website,s and IT systems, and that help us process payments). These third parties may use your information only as directed by us and in a manner consistent withthis Policy. These third parties are prohibited from using or disclosing your information forany other purpose.

Participants in the transaction processing chain

We may share your Personal Data with companies in the transaction processing chain inconnection with processing a payment transaction, such as merchants, banks or other cardissuers, card associations, debit network operators and their members.

Business Transaction

If GDC and any Group Member are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

Professional advisors

We may disclose your Personal Data to professional advisors, such as lawyers, bankers, auditors and insurers, in the course of the professional services that they render to us.

Transfers to third parties

We may disclose your Personal Data to third parties, such as our Media Partners and otherthird-party business partners, in order to provide our services. When we carry out anysharing with third parties, we always ensure that there is an appropriate contract in place,that the information being shared is transferred in a secure way, and that we only share theminimal amount of your information necessary. We will never sell your information to anyother third parties.

Where the third party is a data controller, they have the same obligations under data protection law to protect your data, as we do.

Where the third party is a data processor, we require that these third parties provide asufficient guarantee that the necessary safeguards and controls have been implemented to ensure there is no impact on your data rights and freedoms.

Compliance with Laws and Law Enforcement; Protection and Safety

GDC may disclose information about you to government or law enforcement officials orprivate parties as required by law, and disclose and use such information as we believenecessary or appropriate to (a) comply with applicable laws and lawful requests and legalprocess, such as to respond to subpoenas or requests from government authorities; (b)enforce the terms and conditions that govern our services; (c) protect our rights, privacy,safety or property, and/or that of you or others; and (d) protect, investigate and deteragainst fraudulent, harmful, unauthorized, unethical or illegal activity. GDC may alsodisclose Personal Data in connection with any complaint regarding your use of our websites, for example, in the event of a complaint or legal action arising from a comment or contentposted.

For Rollcard Services

We may share Personal Data with Rollcard’s sponsor bank, service providers and processors,for legal and regulatory purposes, and for fraud prevention and security. Rollcard will notsell Personal Data.

Rollcard uses Plaid Inc. (“Plaid”) to gather your Personal Data from financial institutions. Byusing the Rollcard Service, you grant Rollcard the right, power, and authority to act on yourbehalf to access and transmit your Personal Data from your relevant financial institution.You agree to your Personal Data being transferred, stored, and processed by Plaid. For moreinformation about Plaid, please visit Plaid’s Privacy Policy.

Rollcard uses Bloomreach for its customer relationship management system in whichRollcard sets up all its marketing customer relationship management email campaigns. Formore information about Bloomreach, please visit Bloomreach’s Privacy Policy:
https://www.bloomreach.com/en/legal/privacy.

Rollacrd uses Bloomreach for its customer relationship management system in   which Rollcard sets up all its marketing customer relationship management   email campaigns. For more information about Bloomreach, please visit   Bloomreach’s Privacy Policy.

Rollcard uses Postmark for its transactional customer relationship management emailsystem and for trigger emails from Rollcard’s mobile application. For more informationabout Postmark, please visit Postmark’s Privacy Policy:
https://www.activecampaign.com/legal/privacy-policy.

6. INTERNATIONAL TRANSFERS OF DATA

GAMB is incorporated in the Channel Island of Jersey and GDC operates globally, withprimary offices in United States and Ireland. The mailing address of our principal executiveoffices is 22 Greenville St., St. Helier, Channel Island of Jersey JE4 8PX. Your personal datamay be transferred to other locations outside of your state, province, country or othergovernmental jurisdiction where we, our third-party partners, including our Media Partners,or our service providers maintain offices and where privacy laws may not be as protectiveas those in your jurisdiction. If we make such a transfer, we will require that the recipientsof your personal data provide data security and protection in accordance with applicablelaw; and we will take all the steps reasonably necessary to ensure that your data is treatedsecurely and in accordance with this Privacy Policy and no transfer of your Personal Datawill take place to an organisation or a country unless there are adequate controls in placeincluding the security of your data and other personal information.

European users should read the important information provided below in Section 10 abouttransfer of personal data outside of your region / country.

7. DATA SECURITY AND DATA RETENTION

We have put in place appropriate security measures which we believe reasonably preventsyour Personal Data from being accidentally lost, used or accessed in an unauthorised way,altered or disclosed. In addition, we limit access to your Personal Data to those employees,agents, contractors, subsidiaries, affiliates and other third parties who have a business needto know. They will only process your Personal Data on our instructions, and they are subjectto a duty of confidentiality. We have put in place commercially reasonable procedures todeal with any suspected Personal Data breach and will notify you and any applicableregulator of a breach where we are legally required to do so.

As we seek to use reasonable physical, electronic, and procedural measures to safeguardPersonal Data within our organization against loss, theft, and unauthorized use, disclosure,or modification, however, no data transmission over the internet can be guaranteed to be100% secure. As a result, while we strive to protect your information, we cannot guaranteeits security.

We will process and store the relevant Personal Data for as long as it is necessary for thepurposes set out in this Privacy Policy or required in order to fulfil our legal, contractual, orstatutory obligations and/or for the establishment, exercise or defence of legal claims.

We will also retain Usage Data for internal analysis purposes. Usage Data is generallyretained for a shorter period, except when this data is used to strengthen the security or toimprove the functionality of our services, or we are legally obligated to retain this data forlonger time periods.

If, during your use of our websites, you post comments, we will keep a record of yourcommenting history. Personal data collected from commenting will be kept for the lifetimeof the article commented on.

8. YOUR RIGHTS AND CHOICES

In this section, we describe the rights and choices available to all users. Users who arelocated in Europe and Brazil should read additional information about their rights inparagraph 10 below; users who are located in California, Virginia and certain other US statesshould read additional information about their rights in the relevant paragraphs below; andusers who are located in Australia, Canada and Mexico should read additional informationin paragraphs 14, 15 and 16 respectively.

Marketing communications

You can ask us to stop sending you marketing messages at any time by contacting us orclicking on the opt-out link included in each marketing message. You may continue toreceive service-related and other non-marketing messages.

Choosing not to provide your Personal Data

Where we request Personal Data directly from you, you do not have to provide it to us. Ifyou decide not to provide the requested information, in some circumstances we may beunable to provide services to you. For example, we may be unable to process yourtransaction.

Accessing, modifying or deleting your information

In some jurisdictions, applicable law may provide a right for individuals to access, modify,or delete their Personal Data in some. You may contact GDC directly using the contactinformation below to request access to, modify or delete your information. We may not beable to provide access to, modify, or delete your information in all circumstances.

Complaints

If you have a complaint about our handling of your Personal Data, you may contact our dataprotection officer using the contact information below. A complaint must be made inwriting. Please provide details about your concern or complaint so that we can investigateit. We will determine whether to take action in response to your complaint, which, if we doso, may include conducting internal discussions with relevant business representatives. Wemay contact you for additional details or clarification about your concern or complaint. Wewill contact you to inform you of our response to your complaint. You also may have a rightto file a complaint with a national or local regulatory agency.

9. PAYMENTS

We may provide paid products and/or services. In that case, we use third-party services forpayment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directlyto our third-party payment processors whose use of your personal information is governedby their Privacy Policy. These payment processors adhere to the standards set by PCI-DSSas managed by the PCI Security Standards Council, which is a joint effort of brands like Visa,Mastercard, American Express and Discover. PCI-DSS requirements help ensure the securehandling of payment information.

The payment processors we work with from time to time and at any time include:

Apple Store In-App Payments: Their Privacy Policy can be viewed here.

Google Play In-App Payments: Their Privacy Policy can be viewed here.

Stripe: Their Privacy Policy can be viewed here.

Authorize.net: Their Privacy Policy can be viewe here.

10. ADDITIONAL INFORMATION FOR EUROPEAN USERS AND BRAZILIAN   USERS

Data Controller

GDC is the data controller for the purpose of the General Data Protection Regulation(“GDPR”), and other applicable data protection laws. This means that GDC is principallyresponsible for looking after your Personal Data and this Policy determines the means andpurposes of processing of Personal Data.

Legal bases for processing

We are required to inform you of the legal bases of our processing of your Personal Data,which are described in the table below. If you have questions about the legal basis of howwe process your Personal Data, please contact us at dataprotection@gdcgroup.com.

Use for new purposes

We may use your Personal Data for reasons not described in this Policy where permitted bylaw and the reason is compatible with the purpose for which we collected it.

How long will we use your Personal Data?

We will use your Personal Data for as long as necessary based on why we collected it andwhat we use it for. This may include our need to satisfy a legal, regulatory, accounting, orreporting requirement.

To determine the appropriate retention period for Personal Data, we consider the amount,nature, and sensitivity of the Personal Data, the potential risk of harm from unauthoriseduse or disclosure of your Personal Data, the purposes for which we process your PersonalData and whether we can achieve those purposes through other means, and the applicablelegal requirements.

In general terms, we will retain your Personal Data for the duration of yourinvolvement/engagement with us and for as long as reasonably necessary afterwards. Thereare also certain types of information which are required to be retained for a certain periodby law.

Your individual legal rights

You have the right to obtain access to, rectification of, erasure of, restriction of PersonalData, portability of Personal Data and to object to the processing of your Personal Data asfollows:

• Access. You are entitled to ask us if we are processing your Personal Data and, if so,for a copy of the Personal Data we hold about you, as well as obtain certain otherinformation about our processing activities.
• Correction. If any Personal Data we hold about you is incomplete or inaccurate, youcan require us to correct it, though we may need to verify the accuracy of the newdata you provide to us.
• Erasure. This enables you to ask us to delete or remove Personal Data where there isno good reason for us continuing to process it. You also have the right to ask us todelete or remove your personal data where you have successfully exercised your rightto object to processing (see below), where we may have processed your informationunlawfully or where we are required to erase your personal data to comply with locallaw. If you are in Brazil, you may also ask us to anonymize or block personal data thatis excessive, unnecessary or where we may have processed your informationunlawfully.
• Object. Where our reason for processing your Personal Data is legitimate interest,you may object to processing as you feel it impacts on your fundamental rights andfreedoms. You also have the right to object where we are processing your PersonalData for direct marketing purposes.
• Restriction. You may ask us to suspend our use of your Personal Data in the following scenarios:
  - if you want us to establish the data's accuracy;
  - where our use of your Personal Data is unlawful but you do not want us to erase it;
  - where you need us to hold your data for a longer period than we usually would, because you need it to establish, exercise or defend legal claims; or
  - you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Transfer. Where it is possible, we will provide to you, or a third party you have chosen,your Personal Data in a structured, commonly used, machine-readable format. Notethat this right only applies to Personal Data provided by you which you initiallyprovided consent for us to use or where we used the information to perform acontract with you.
• Withdraw consent. Where our reason for processing is based on your consent, youmay withdraw that consent at any time. If you withdraw your consent, we may notbe able to provide certain services to you. We will advise you if this is the case at thetime you withdraw your consent.
• Automated decision making. You have the right not to be subject to automateddecision making (e.g., profiling) that significantly affects you. The exercise of this rightis not available to you in the following cases:
  - The automated decision is required to enter into, or perform, a contract with you.
  - We have your explicit consent to make such a decision.
  - The automated decision is authorised by local law of an EU member state.
  However, in the first two cases set out above, you still have the right to obtain human intervention in respect of the decision, to express your point of view and to contest the decision.

If you have any questions about this Policy or wish to exercise any of the rights set out above, please contact us at
dataprotection@gdcgroup.com.

We may need to request specific information from you to help us confirm your identity andensure you are entitled to exercise a right in respect of your Personal Data. This is a securitymeasure to ensure that Personal Data is not disclosed to any person who has no right toreceive it. We may also contact you to ask you for further information in relation to yourrequest to speed up our response.

There may be legal or other reasons why we cannot, or are not obliged to, fulfil a requestto exercise your rights. We will use available lawful exemptions to your individual rights tothe extent appropriate. If we decline your request, we will tell you why, subject to legalrestrictions.

You also have the right to make a complaint at any time to a supervisory authority (for moreinformation go to https://edpb.europa.eu/about-edpb/board/members_en). If you arelocated in the UK, you also have a right to make a complaint to the InformationCommissioner’s Office (ICO).

International transfers of data

We may transfer the Personal Data we collect about you to recipients in countries otherthan your country, including the United States. These countries may not have the same dataprotection laws as the country in which you initially provided the information. When wetransfer your Personal Data to other countries, we will protect that information as describedin this Policy or as otherwise disclosed to you.

We comply with applicable legal requirements when transferring Personal Data to countriesother than the country where you are located. If you are located in the EEA, the UK orSwitzerland, we will transfer your Personal Information in accordance with adequacydecisions, standard contractual clauses, and other data transfer mechanisms.

See list of countries for which the European Commission has issued an adequacy decision here.

See list of countries for which the UK government has issued an adequacy decision here.

11. INFORMATION FOR CALIFORNIA RESIDENTS

Your Data Protection Rights under the California Consumer Privacy Act

We are required by the California Consumer Privacy Act of 2018, as amended by theCalifornia Privacy Rights Act of 2020 (CPRA), (“CCPA”) to provide California residents withinformation about how we collect, use and share their Personal Data, and of the rights andchoices we offer California residents regarding our handling of the Personal Data. Certainterms used in this section have the meanings given to them in the CCPA.

Your California privacy rights

As a California resident, you may have the rights listed below. However, these rights are notabsolute, and we may decline your request as permitted by the CCPA.

• Know and Access . You may have the right to request that we disclose to you informationabout our collection and use of your personal data, including: (a) the categories of andspecific pieces of personal data we collect about you; (b) the categories of sources fromwhich we collect personal data; (c) the business or commercial purpose for which wecollect, sell or share personal data; and (d) the categories of third parties to whom wedisclose personal data. You may only make an access request to us for your personal dataup to two times in any 12-month period.
• Deletion. You may have the right to request that we delete certain personal data that wehave collected about you.
• Correction. You may have the right to request that we correct inaccuracies in the personaldata we maintain about you.
• Data Portability. You may have the right of portability, or the right to have us transfer yourpersonal information to other persons or entities twice in a 12-month period, upon their request.
• Right to opt-out of sale or sharing. You may have the right to opt out of the sale of yourpersonal information or the disclosure of your personal information for targeted orbehavioral advertising purposes.
• Non-discrimination. You are entitled to exercise the rights described above free fromdiscrimination. This means that we will not penalize you for exercising your rights by takingactions such as by denying you goods or services, increasing the price/rate of goods orservices, decreasing the service quality, or suggesting that we may penalize you asdescribed above for exercising your rights. However, the CCPA allows us to charge you adifferent price or provide a different service quality if that difference is reasonably relatedto the value of the Personal Data we are unable to use.

We do not use your sensitive personal information for purposes other than those allowed by the CCPA as set out in Cal. Code Regs. tit. 11 § 7027(m).

How to exercise your rights

You may exercise your California privacy rights by submitting a request to us atdataprotection@gdcgroup.com or calling us at +1.646.809.5460. We will verify the identityof the individual submitting the request before providing a substantive response to therequest. A request must be provided with sufficient detail to allow us to understand,evaluate and respond. The requester must provide sufficient information to allow us toreasonably verify that the individual is the person about whom we collected information.California residents can empower an “authorized agent” to submit requests on theirbehalf. We will require the authorized agent to provide proof of their authority, and wemay require the individual to verify their identity directly.

We will respond to requests as required by applicable law. Within 10 days of receiving yourrequest, we will confirm receipt of the request and provide information about how we willprocess it. Generally, we will respond to your request free of charge within 45 days ofreceiving your verifiable request. The time period to provide the required information maybe extended once by an additional 45 days when reasonably necessary and with priornotice. We may deny a request if we cannot verify identity, or if the law otherwise permits.

As discussed above, we do not sell your personal information for monetary consideration.However, we may collect and use certain of your information collected automaticallythrough our website for personalization and analytics, some of which may be conside redbehavioral or targeted advertising under applicable law. To the extent we “sell” or “share”your personal information, California residents may opt-out of such sale or sharing asdescribed below.

Sale or Sharing of Personal Information for cross-context advertising means

Our business model does not include selling your personal information to third parties inexchange for money. However, our websites and online services may use analytics andadvertising tools, such as cookies, pixels, and server-side data integrations, that enable usand our analytics and marketing partners to collect and disclose identifiers, internet or otherelectronic network activity information, commercial information, and inferences based onyour activity across our services and websites and over time and across third-party websitesor online services, including to analyze your usage of our services and to serve youadvertisements that are relevant to you (“cross-context behavioral advertising”). Under theCCPA, sharing personal information with partners in exchange for some benefit, such asproviding more relevant ads, can be considered a “sale” or “sharing” (as those terms aredefined in the CCPA) in some circumstances. As such, we may be conside red to “sell” or“share” or otherwise process these categories of your personal information for targeted orcross-contextual behavioral advertising. However, please note that we do not knowingly sellor share the personal information of consumers under 16.

To the extent we “sell” or “share” your personal information, you may opt out of that “sale”or “sharing” on a going-forward basis at any time as described below. You may also be ableto restrict the collection of personal information through your device’s operating system or by disabling cookies, but doing so may prevent you from using the functionality of thewebsites. If your browser supports it, you can turn on the Global Privacy Control (GPC) toopt out of the “sale” or “sharing” of your personal data. We honor the GPC and otheruniversal opt out signals where we are required to do so by applicable law. These are signalsyou can send from your browser to a website to convey your choice to exercise certain optout rights granted by individual states.

Some internet browsers have a “Do Not Track” feature that lets you tell websites that youdo not want to have your online activities tracked. Given that there is not a uniform waythat browsers communicate the “Do Not Track” signal, our website does not currentlyinterpret, respond to or alter its practices when it receives “Do Not Track” signals.

Even if you opt out of the sharing or processing of your California Personal Information fortargeted or cross-context behavioral advertising, you may still see our ads online at othersites and apps, and we may still base aspects of ads on your interactions with us and thewebsites.

Personal information that we collect, use and share

The table below summarizes what data we may collect or what data may have beencollected from California residents during the last 12 months before the effective date ofthis Policy.

Please note that the categories and examples provided in the list below are those definedin the CCPA. This does not mean that all examples of that category of personal informationwere in fact collected by GDC but reflects our good faith belief to the best of our knowledgethat some of that information from the applicable category may be and may have beencollected. For example, certain categories of personal information would only be collectedif you provided such personal information directly to us.

We may collect, use, disclose for business or commercial purposes, or otherwise process(and may have collected, used, disclosed for business or commercial purposes, or otherwiseprocessed in the 12-month period prior to the effective date of this Policy) personalinformation from the sources identified in Section 3 “Collection of Personal Data” for thepurposes described in Section 4 “Use of Personal Data” to the categories of entitiesdescribed in Section 5 “To Whom Do We Provide Personal Data.”

Please note that our website is not intended for or designed to attract children under theage of 18, and we will not knowingly solicit or collect personal information from children weactually know are under 18.

12. INFORMATION FOR VIRGINIA RESIDENTS

Under the Virginia Consumer Data Protection Act, Virginia residents have the followingrights around GDC’s collection, use and disclosure of their personal data. For purposes ofexercising the rights in this section, the listed terms are defined as follows:

Definitions:

• Profiling means any form of automated processing to evaluate, analyze or predictpersonal aspects related to a person’s economic situation, health, personal preferences,interests, reliability, behavior, location, or movements.
• Sale of personal data means the exchange of personal data for monetary consideration.
• Targeted advertising means displaying advertisements to a consumer where theadvertisement is selected based on personal data obtained from that consumer’sactivities over time and across non-affiliated websites or online applications to predictsuch consumer’s preferences or interests.

As a Virginia resident, you may have the rights listed below.

• Right of access. You may have the right to confirm whether we are processing your personal data and to access your personal data.
• Right of data portability. You may have the right to request that we provide you a copy of the personal data that you previously provided to GDC.
• Right to correction. You may have the right to request that we correct inaccuracies in the personal data we have collected about you.
• Right to deletion. You may have the right to request that we delete certain personal datathat we have collected about you. The foregoing is subject to our right to maintain yourpersonal data for specific purposes permitted under applicable state law. If we areunable to comply with any such request, we will notify you.
• Right to opt-out. You may have the right to request that your personal data not be soldto third parties or used for targeted advertising or profiling in furtherance of decisionsthat produce legal or similarly significant effects concerning you.
• Appeal. You may have the right to appeal GDC’s denial of any of the above-listed rights.You may do so by responding to the message in which GDC has communicated its denialand indicating you would like to appeal that denial.

How to exercise your rights

If you are a Virginia resident, you may exercise your rights by contacting us at
dataprotection@gdcgroup.com

13. OTHER STATES OF THE UNITED STATES PRIVACY RIGHTS

The States of Colorado, Connecticut, Florida and Utah each provide their state residents with rights to:

• Confirm whether we process their personal information.
• Access, correct and delete certain personal information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales.

The States of Colorado and Connecticut also each provide their state residents with rights to:

• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

If you are a resident of any of these states, you may exercise any of these rights by contacting us at dataprotection@gdcgroup.com.

The State of Nevada provides its residents with a limited right to opt-out of certain personalinformation sales. Residents who wish to exercise this sale opt-out rights may submit arequest to this designated address: dataprotection@gdcgroup.com. However, we do notcurrently sell data triggering that statute’s opt-out requirements

The State of Iowa provides their state residents with rights to:

Rights to access. Consistent with applicable law, you may submit a verifiable consumerrequest to access, the personal information that we have collected about you as well asmore information about our data practices. For more information about how we collect,use, and disclose personal information for business purposes, please review our GlobalPrivacy Policy.

Rights to delete. Consistent with applicable law, you may submit a request to delete your personal information.

Right to data portability. Consistent with applicable law, you have the right to obtain a copyof the personal data they provided to the controller, except when such data is subject tosecurity breach protection, or previously provided to the controller in a portable and readily usable format that allows the consumer to transmit the data to another controller withouthindrance, where processing is carried out by automated means.

Appeal of Consumer Rights Requests. To appeal a refusal to take action on your request,please see the instructions in our response to your request or submit your appeal in writingby contacting dataprotection@gdcgroup.com with the subject “Appeal of Consumer RightsRequest.”

The States of Delaware, Montana, New Hampshire, New Jersey, Oregon and Tennessee provide their state residents with rights to:

Right to Access. Consistent with applicable law, you may submit a verifiable consumerrequest to access the personal information that we have collected about you as well as moreinformation about our data practices. For more information about how we collect, use, anddisclose personal information for business purposes, please review our Global PrivacyPolicy.

Right to Correct. Consistent with applicable law, you may submit a verifiable consumerrequest to correct inaccuracies in your personal information held by GDC.

Right to Delete. Consistent with applicable law, you may submit a verifiable consumerrequest to delete your personal information.

Appeal of Consumer Rights Requests. To appeal a refusal to take action on your request,please see the instructions in our response to your request or submit your appeal in writingby contacting dataprotection@gdcgroup.com with the subject “Appeal of Consumer RightsRequest.”

Personalized Advertising Opt-Out. We do not sell personal information. However, we mayprocess personal information for purposes of displaying advertisements that are selectedbased on users’ online activities over time and across different sites, services, and devices.Consistent with applicable law, you may opt out of such processing by contacting us. Westrive to honour opt-out preference signals where required by applicable law. The opt-outpreference signals are offered by a third party that we do not control.

The State of Washington provide their state residents with rights to:

Right to Access. Consistent with applicable law, you may submit a request to access thepersonal information that we have collected about you as well as more information aboutour data practices. For more information about how we collect, use, and disclose personalinformation for business purposes, please review our Global Privacy Policy.

Right to Correct. Consistent with applicable law, you may submit a request to correct inaccuracies in your personal information held by GDC.

Right to Delete. Consistent with applicable law, you may submit a request to delete your personal information.

Right to data portability. Consistent with applicable law, you have the right to obtain a copy of the personal data they provided to the controller.

Right to Opt Out. Consistent with applicable law, you can opt out of certain data processing activities, namely data processing for targeted advertising, data sales, and profiling.

Appeal of Consumer Rights Requests. To appeal a refusal to take action on your request,please see the instructions in our response to your request or submit your appeal in writingby contacting dataprotection@gdcgroup.com with the subject “Appeal of Consumer RightsRequest.”

Please note that in case of submitting data subject rights requests, you may need to verifyyour identity and request before further action is taken. As a part of this process, you maybe required to provide personal information, such as your name, state of residence, phonenumber and email address associated with your account, if applicable. Consistent withapplicable laws, you may designate an authorized agent to make a request on your behalf.

14. INFORMATION FOR AUSTRALIA RESIDENTS

GDC is providing the following additional information for individuals whose personalinformation is collected or held by us at a time when the collecting or holding entity has an“Australian link” within the meaning of the Australian Privacy Law.

Where you are such an individual, you may make a complaint to us about a breach of the Australian Privacy Principles by contacting us at dataprotection@gdcgroup.com.

We will investigate your complaint and endeavour to resolve any issue to your satisfaction. If we do not adequately answer your concerns, you will have the right to make a complaint in writing to the Office of the Australian Information Commissioner here.

If at any time you want to know what personal information we hold about you, you may request access to your record by contacting us and we will respond within a reasonable period from the date your application is received.

If at any time you want to change personal information that is inaccurate or out of date, please contact us and we can amend the record. If you want to have your personal information deleted, please let us know and we will take reasonable steps to delete it unless we need to keep it for legal or regulatory purposes.

15. INFORMATION FOR CANADA RESIDENTS

We may collect, use, and disclose Personal Data for the purposes identified in this Privacy Policy, and for any additional purposes, as required by law, with notice to you and your express or implied consent.

You may be able to take advantage of the tool developed by the Digital Advertising Alliance of Canada to opt out of third-party advertising. Where available, this tool provides a list of parties that may target advertisements based on your online web-browsing activities and the ability to opt out of their use of your information for that purpose. To access the tool, visit https://youradchoices.ca/.

If you have a question or a complaint about our handling of your personal information, please contact us at dataprotection@gdcgroup.com. We will respond to your complaint within a reasonable time. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner.

16. INFORMATION FOR MEXICO

Please see below information regarding GDC privacy practices as relates to Mexico’s Federal Law for the Protection of Personal Data Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares).

You have the following ARCO rights regarding GDC's handling of your personal information: theright to access your personal information and request explanations about how GDC uses thisinformation, the right to correct inaccurate or incomplete data, the right to cancel your data ifyou believe it is not being used in accordance with the principles, duties and obligations set forthin Mexican law regarding data protection, and the right to object to GDC's processing of yourdata for certain purposes. These rights are known under Mexican law as the “ARCO rights.” Toexercise your ARCO rights, please submit your request at dataprotection@gdcgroup.com.Please indicate “Exercise of ARCO rights/Mexico” at the beginning of your request.

Please note that GDC, as a data controller, may deny you the exercise of your ARCO rights in thecases permitted by applicable law and will inform you of such decision. The refusal may bepartial, in which case GDCwill carry out the access, rectification, cancellation or objection in therelevant part.

Data Transfers. GDC, as a data controller, will ensure that third parties to whom the data istransferred comply with the principles and obligations set out in the Federal Law for theProtection of Personal Data Held by Private Parties.

If a data breach compromising personal data occurs, GDC as a data controller will notify you, asan affected data subject, and the National Institute for Transparency, Access to Information,and Personal Data Protection (INAI).

17. LINKS TO OTHER WEBSITES

In the provision of our services, on our websites and on the websites of our Media Partners, wemay link to third-party websites, mobile applications, and other content. GDC is not responsiblefor the privacy practices of any such third party, and this Policy does not apply to such third party’s websites, mobile applications, or other content. GDC does not guarantee, approve,or endorse any information, material, services, or products contained on or availablethrough any such linked third-party website, mobile application, or other content. GDC isnot responsible for any content on any such third-party properties to which we link

18. COOKIES, PIXEL AND TRACKING INFORMATION

Cookies are small pieces of data served on your computer that remember what you enterwhile you're browsing a website. For more information about cookies and how they work,please visit: www.aboutcookies.org.

We use cookies, pixels, and similar technologies to improve our service, and to enhanceyour user experience, for example, to show you the most relevant information when youreturn to our site.

When we use cookies, pixels and similar technologies, we may process information thatcould be linked to you, such as your IP address, device identifiers, and browsing behavior.Where required by applicable law (including the GDPR and ePrivacy Directive for Europeanusers), we will obtain your consent before placing non-essential cookies or similar trackingtechnologies on your device. You can manage cookie usage, disable or delete cookiesthrough your browser settings at any time. The help function in your preferred browsershould provide you with the correct information.

Like many other companies which offer online services to their clients/customers, we useservices provided by Google (including Google Analytics GA4 with Google Signals enabled,Google Ads via Google Tag Manager, and Google AdSense), Meta (including the Meta Pixeland the Meta Conversions API, a server-side integration), Microsoft (including the MicrosoftUET Tag and Microsoft Clarity), TikTok (via the TikTok Pixel), Snapchat (via the SnapchatPixel), Pinterest (via the Pinterest Tag), Reddit (via the Reddit Pixel), X (formerly Twitter, viathe X Pixel), Everflow (for affiliate conversion tracking), and other companies that usetracking technology. These services collect information about your browsing activity on ourwebsites through cookies, pixels, and similar technologies, as well as through server-sidedata transfers (such as the Meta Conversions API, which transmits event data directly fromour servers to Meta). The purposes of these services include providing interest-basedadvertising optimized for effectiveness based on inferences about you, measuring theperformance of advertising campaigns, attributing conversions, conducting analytics onhow our websites are used, and building audience segments for retargeting. Your choicesto adjust your preferences for interest-based advertising, and/or opting-out of use of yourpersonal information by these companies for such advertising, include:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies,including cookies used for interest-based advertising. To do this, follow the instructionsin your browser settings. Many browsers accept cookies by default until you changeyour settings. For more information about cookies, including how to see what cookieshave been set on your device and how to manage and delete them, visitallaboutcookies.org.
• Using privacy plug-ins or browsers. You can block our websites from setting cookiesused for interest-based ads by using a browser with privacy features, like Brave, orinstalling browser plugins like Privacy Badger, Ghostery, or uBlock Origin, andconfiguring them to block third-party cookies/trackers.
• Platform opt-outs. The following advertising partners offer opt-out features that let youopt-out of the use of your information for interest-based advertising:
  - Google
  - Meta (Facebook)
  - Criteo
  - Wunderkind
  - TikTok
  - Snapchat
  - Reddit
  - X (formerly Twitter)
  - Pinterest
  - Microsoft
• Advertising industry opt-out tools. Some of our business partners that collect informationabout users’ activities may be members of organizations or programs that provide choicesto individuals regarding the use of their browsing behavior or mobile application usage forpurposes of targeted advertising. You can use the following opt-out options to limit the useof your information for interest-based advertising by participating companies:
  - Digital Advertizing Alliance
  - Network Advertising Initiative
  - European users may opt-out of receiving targeted advertising on websites throughmembers of the European Interactive Digital Advertising Alliance by clicking here, selectingthe user’s country, and then clicking “Choices” (or similarly titled link).
  - We also may work with companies that offer their own opt-out mechanisms and may notparticipate in the opt-out mechanisms we linked above.

As noted above, if you choose to opt-out of targeted advertisements, you will still seeadvertisements online, but they may not be relevant to you. Even if you do choose to optout, not all companies that serve online behavioral advertising are included in this list, soyou may still receive some cookies and tailored advertisements from companies that arenot listed.

More information on how to deactivate or delete cookies can be found below as well as onhttps://www.aboutcookies.org/cookie-faq/.

Some browsers provide helpful cookie guides:

• Chrome:   https://support.google.com/chrome/bin/answer.py?hl=en&answer=9564  7&p=cpn_cookies
• Firefox: http://support.mozilla.org/en-US/kb/Cookies
• Internet Explorer: http://support.microsoft.com/kb/278835
• Safari 5 for Mac: https://support.apple.com/e
• Opera: http://help.opera.com/Linux/10.50/en/cookies.html

In addition, Google Analytics provides its own opt-out options:

• http://tools.google.com/dlpage/gaoptout

In the case of mobile devices, it may be necessary to consult the device’s instruction manualto manage cookies effectively. Restriction of cookies may have an impact on thefunctionality of our websites.

TYPES OF COOKIES

We may use cookies for different purposes and with different functions.

Essential cookies are necessary for our websites to work effectively. They help to make ourwebsites usable by enabling basic functionalities such as page navigation and accessibilityto secure areas of our websites. Cookies of this nature may also be used to protect andaccelerate our websites for security reasons and to identify our trusted visitors. They mayfilter bots and distinguish them from legitimate users, preventing any form of spam activityon our websites.

Preference cookies enable our websites to remember information that changes the way ourwebsites behave or look. They may also be used to provide services you have asked for.

Analytics cookies analyse information about how our websites are being used. Analyticscookies can process information about the number of visitors to our websites, wherevisitors to our websites came from, the pages they visit, scrolling activities, downloads,information about user agents, time spent on our websites and approximate geo-locationof a device that you use to access our websites. We use this information to compile reportsthat help us to improve our websites.

In case we allow others to service cookies through our websites and/or apps, these cookiesare called “third party cookies”. Third-party cookies can be used for a variety of purposes,including site analytics, advertising, and social media features.

Below is more information about most common cookies that we use, how they are used,and how long they will be stored on your computer or device.

Our most common cookies and other tracking technologies are:

We also use the following additional tracking pixels and technologies on our websites:

Snapchat Pixel – Placed by Snap Inc. The Snapchat Pixel is used to track conversions fromSnapchat advertisements, build audience segments for retargeting, and measure advertisingperformance. The Snapchat Pixel may collect information such as IP address, browser type,page URL, and actions taken on our websites. For more information, visit Snap Inc.’s Privacy Policy: https://snap.com/en-US/privacy/privacy-policy. You can manage your Snapchatadvertising preferences at: https://support.snapchat.com/a/advertising-preferences.

Everflow Conversion Pixel – Placed by Everflow. The Everflow conversion pixel is used to trackand attribute conversions from affiliate marketing campaigns. It collects information such asclick identifiers, conversion events, and referral source data to measure the performance ofour affiliate partnerships. For more information, visit Everflow’s Privacy Policy:https://www.everflow.io/privacy-policy.

Reddit Pixel – Placed by Reddit, Inc. The Reddit Pixel is used to track conversions from Redditadvertisements, build audience segments for retargeting, and measure advertisingperformance on the Reddit platform. The Reddit Pixel may collect information such as IPaddress, browser type, user agent, and actions taken on our websites. For more information,visit Reddit’s Privacy Policy: https://www.reddit.com/policies/privacy-policy. You can manageyour Reddit advertising preferences at: https://www.reddit.com/settings/privacy.

Pinterest Tag – Placed by Pinterest, Inc. The Pinterest Tag is used to track conversions fromPinterest advertisements, build audience segments for retargeting, and measure advertisingperformance. The Pinterest Tag may collect information such as IP address, browser type, andactions taken on our websites. For more information, visit Pinterest’s Privacy Policy:https://policy.pinterest.com/en/privacy-policy. You can manage your Pinterest advertisingpreferences at: https://help.pinterest.com/en/articles/personalization-and-data.

X (formerly Twitter) Pixel – Placed by X Corp. The X Pixel is used to track conversions from Xadvertisements, build tailored audience segments for retargeting, and measure advertisingperformance. The X Pixel may collect information such as IP address, browser type, and actionstaken on our websites. For more information, visit X’s Privacy Policy: https://x.com/en/privacy.You can manage your X advertising preferences at:https://x.com/settings/account/personalization.

Please note that our advertisers may also use cookies on their websites, and we   have no control over such use.

Other Technologies.

We may use other similar technologies to collect information automatically. Other suchtools that we, our vendors, and third parties may use include:

• Server logs. These logs record information about the device, browser, operating system,network, and other resources you use to access our digital services.
• Web pixels. These are small electronic images deployed on websites and emails thatcollect information about how users interact with content. Unlike cookies, which are storedon the hard drive of your computer or mobile device by a website, pixel tags are embeddedinvisibly on webpages or within HTML formatted emails. Pixel tags are used to demonstratethat a web page was accessed or that certain content was viewed, typically to measure thesuccess of our marketing campaigns or engagement with our emails and to compilestatistics about usage of the Sites, so that we can manage our content more effectively.

We may further use third-party service providers to show advertisements to you to helpsupport and maintain our services:

AdMob by Google

AdMob by Google is provided by Google Inc.

You can opt-out from the AdMob by Google service by following the instructions describedby Google: https://support.google.com/ads/answer/2662922?hl=en

For more information on how Google uses the collected information, please visit the “HowGoogle uses data when you use our partners' sites or app” page:http://www.google.com/policies/privacy/partners/ or visit the Privacy Policy of Google:http://www.google.com/policies/privacy/

AdButler  

AdButler is an advertising service provided by Sparklit Networks Inc.

For more information about AdButler, please visit their Privacy Policy:https://www.sparklit.com/agreements.spark?agreement=privacy

Unity Ads

Unity Ads is provided by Unity Technologies.

You can opt-out from Unity Ads service by following the instructions as described by UnityTechnologies on their Privacy Policy page: https://unity3d.com/legal/privacy-policy

For more information about Unity Technologies, please visit Unity Technologies PrivacyPolicy: https://unity3d.com/legal/privacy-policy

If you have any questions about this Policy or you wish to exercise any of the rights set outabove, please contact us at dataprotection@gdcgroup.com.

We will respond to all legitimate requests promptly and, in any event, within anytimeframes prescribed by applicable law. In general, we must respond to queries within onemonth from the receipt of the request. Occasionally, it may take us longer than a month ifyour request is particularly complex or you have made a number of requests. In this case,we will notify you and keep you updated.

19. BEHAVIORAL REMARKETING

We may use remarketing services to advertise on third party websites to you after youvisited our service. We and our third-party vendors use cookies to inform, optimise andserve ads based on your past visits to our service.

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the GoogleDisplay Network ads by visiting the Google Ads Settings page:http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on –https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Optout Browser Add-on provides visitors with the ability to prevent their data from beingcollected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google PrivacyTerms web page: https://policies.google.com/privacy?hl=en

Bing Ads Remarketing  

Bing Ads remarketing service is provided by Microsoft Inc.  

You can opt-out of Bing Ads interest-based ads by following their instructions:https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

You can learn more about the privacy practices and policies of Microsoft by visiting theirPrivacy Policy page: https://privacy.microsoft.com/en-us/PrivacyStatement

X (formerly Twitter)

X remarketing service is provided by X Corp. (formerly Twitter, Inc.).

You can opt-out from X’s interest-based ads by following their instructions:https://x.com/settings/account/personalization

You can learn more about the privacy practices and policies of X by visiting their PrivacyPolicy page: https://x.com/en/privacy

Pinterest

Pinterest remarketing service is provided by Pinterest Inc.

You can opt-out from Pinterest's interest-based ads by enabling the “Do Not Track”functionality of your web browser or by following Pinterest instructions:http://help.pinterest.com/en/articles/personalization-and-data

You can learn more about the privacy practices and policies of Pinterest by visiting theirPrivacy Policy page: https://about.pinterest.com/en/privacy-policy

Meta (Facebook)

Meta remarketing services are provided by Meta Platforms, Inc. We use the Meta Pixeland the Meta Conversions API to deliver targeted advertisements to you on Metaplatforms (including Facebook and Instagram) based on your activity on our websites.

You can opt-out of Meta’s interest-based advertising by visiting your Meta ad settings:https://www.facebook.com/about/ads

You can learn more about the privacy practices and policies of Meta by visiting theirPrivacy Policy page: https://www.facebook.com/privacy/policy/

TikTok

TikTok remarketing service is provided by TikTok Inc. (ByteDance Ltd.). We use the TikTokPixel to deliver targeted advertisements to you on the TikTok platform based on youractivity on our websites.

You can opt-out of TikTok’s interest-based advertising through your TikTok accountsettings or by visiting: https://www.tiktok.com/legal/privacy-policy

You can learn more about the privacy practices and policies of TikTok by visiting theirPrivacy Policy page: https://www.tiktok.com/legal/privacy-policy

Snapchat

Snapchat remarketing service is provided by Snap Inc. We use the Snapchat Pixel to delivertargeted advertisements to you on the Snapchat platform based on your activity on ourwebsites.

You can opt-out of Snapchat’s interest-based advertising through your Snapchat accountsettings or by visiting: https://support.snapchat.com/a/advertising-preferences

You can learn more about the privacy practices and policies of Snap by visiting theirPrivacy Policy page: https://snap.com/en-US/privacy/privacy-policy

Reddit

Reddit remarketing service is provided by Reddit, Inc. We use the Reddit Pixel to delivertargeted advertisements to you on the Reddit platform based on your activity on ourwebsites.

You can opt-out of Reddit’s interest-based advertising through your Reddit accountsettings at: https://www.reddit.com/settings/privacy

You can learn more about the privacy practices and policies of Reddit by visiting theirPrivacy Policy page: https://www.reddit.com/policies/privacy-policy

20. UPDATES TO THIS POLICY

As we may make changes to this Policy from time to time, you can always find an up-to-dateversion of this Policy on our websites.

This Policy was updated as of April 29, 2026