PRIVACY POLICY FOR KRATOS GAMING NETWORK

Preliminary

This privacy policy (“Privacy Policy”) is issued by Kratos Studios Limited (“KGeN” or “Us” or “We” or “Our”) and forms a legally binding agreement between You and KGeN. It applies to Your use of the Platform and Our Services and governs the manner in which any data from which You can be identified (“Personal Data”) is collected, processed, stored, transferred, and used by Us under Applicable Law, including the Information Technology Act 2000 (collectively “Data Protection Laws”).

THIS PRIVACY POLICY IS PART OF OUR TERMS OF USE AND SHALL BE SUBJECT TO AND READ ALONG WITH OUR TERMS OF USE, AVAILABLE AT [insert link]. ALL CAPITALIZED TERMS USED AND NOT DEFINED HEREIN SHALL HAVE THE MEANING ASCRIBED TO THEM UNDER THE TERMS OF USE.

This Privacy Policy does not apply to any information or data You provide to a third-party, including our Game Partners and Service Providers, with whom You interact through Our Platform. We are not responsible for the privacy practices of such third parties, and You must read and understand the privacy practices of such third parties before availing their service.

Please read this Privacy Policy carefully before using the Platform or availing Our Services. By visiting the Platform or setting up an account with Us, You accept and agree to be bound by this Privacy Policy. IF YOU DO NOT CONSENT TO THE COLLECTION AND USE OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORM.

THE INFORMATION WE COLLECT AND HOW WE USE IT

By accessing or using the Platform, You consent to providing Us Your Personal Data and agree to Our Privacy Policy.

We may collect and receive Personal Data from You when You access Our Platform, register for a User Account with Us, or when You connect Your User Account with an external third-party.

We may monitor the use of the Platform through the use of cookies and similar tracking devices. To illustrate, We may monitor the number of times You visit the Platform or which pages You viewed. This information helps Us to build Your profile and render better Services to You. Some of this data will be aggregated or statistical, which means that We will not be able to identify You individually.

The following table lists the information We may collect from You and how We will use it.

You also specifically agree and consent to Us collecting, storing, processing, transferring, and sharing information (including Personal Data) related to You with Our Game Partners or Service Providers to customize and provide better services to You.

We do not allow users who are below the age of 18 (eighteen) to create a User Account, nor intentionally gather Personal Data from such users.

SHARING OF YOUR INFORMATION

You have the right to decide how we share and use your Personal Data by modifying the privacy settings of your User Account. Any Personal Data that we share will be in accordance with these privacy settings.

We will disclose or share Your Personal Data, without notice, for the primary purposes for which it was collected in accordance with this Privacy Policy, including, without limitation:

• where You have consented to such disclosure or sharing;

• where permitted under the applicable Data Protection Laws;

• where required under Applicable Laws;

• where it is necessary to protect and defend the rights or property of Kratos, our Service Provider, our Game Partners, and/or our users;

• where it is necessary to act under exigent circumstances to protect the personal safety of other users on the Platform, or the general public visiting the Platform.

Sharing with Service Providers

We work with Our Service Providers to execute various functionalities of the Platform and We may share Your information with them to enable and better customize Our Services for You.

Sharing with Game Partners

We may share Your Personal Data with Our Game Partners and their respective service providers for, inter alia, helping you experience and engage with the Game Partner’s services on the Platform.

Sharing with B2B partners

We may partner with businesses and third-party brands to sponsor some incentives or advertise relevant products to You and may share Your Personal Data with such third parties to help them give You incentives or show user-specific advertisements.

Sharing with group companies

Subject to Applicable Law, We may share any data, including Personal Data, that We collect from You with Our group companies for product research and development; making Our Services better; and tailoring the Platform for Your benefit.

Sharing with law enforcement when needed

We will share Your information, without prior notice, on a request from any competent governmental authority or a court of competent jurisdiction or law enforcement officers that We find appropriate or necessary in order to comply with Applicable Law.

For the purpose of providing Our Services, we may share any data, including Personal Data, with third parties internationally and you consent to such sharing of data in order to avail Our Services.

Security of Your Information

We strive to maintain the security and safety of Your Personal Data in line with industry standards. Once We have received Your information or Personal Data, We use strict procedures and security features as per industry standards and the Data Protection Laws to try to prevent unauthorised access, loss, misuse, unauthorised disclosure and dissemination, destruction and alteration of Your Personal Data.

Steps taken to ensure Personal Data security:

• All data is hosted on third-party servers having security standards as per global benchmarks.

• We employ industry standard data security practices to keep Your Personal Data safe from cyber-attacks and threats.

• We undertake periodic assessments of the Platform’s safety and security practices.

You are responsible to keep Your credentials for accessing the Platform personal and confidential. You should not share Your password or login details with anyone. We will not be responsible for any liability or obligation You might face due to Your sharing of Your User Account details with anyone.

While We sincerely strive to protect Your Personal Data, We cannot guarantee its security, or warrant that no harmful code will enter the Platform (including but not limited to viruses, bugs, trojan horses, spyware, malware, forks or adware). Transmission of information through the internet is not completely secure. You should be aware of the risks associated with disclosing any information or transacting over the internet or when using online portals.

We urge You to take every precaution when using the internet to disclose Your Personal Data to Us, including using strong passwords, changing Your password regularly and using a secure browser. ANY INFORMATION YOU PROVIDE US IS AT YOUR OWN RISK AND DISCRETION.

You agree to immediately notify Us if You discover or otherwise suspect any security issues related to any of Our Services or Your User Account. You can contact Us at contact@kgen.io.

Our Cookie Policy

Please note that We use “cookies” to help personalize Your online experience.

A cookie is a text file that is placed on Your hard drive by a web page server. Cookies cannot be used to run programs or deliver viruses to Your device. Cookies are uniquely assigned to You and can only be read by a web server in the domain that issued the cookie to You.

Cookies may be either persistent cookies or session cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that We store about You may be linked to the information stored in and obtained from cookies.

We place cookies on certain pages of the Platform in order to help and analyze Our webpage flow, track user trends, measure promotional effectiveness, and promote trust and safety. We offer certain additional features on the Platform that are only available through the use of a “cookie”. We place both permanent and temporary cookies in Your device’s hard drive.

Cookies on the Platform may be used to ensure a smooth User experience, perform analytics, and for showing relevant advertisements. Please note that third parties (such as Game Partners, Service Providers, analytical software providers, etc.) may also use cookies, over which We have no control.

Most web browsers automatically accept cookies but You can usually modify Your browser setting to disable, block or deactivate cookies if You so prefer. If You choose to decline cookies, You may not be able to access all or parts of Our Platform or to fully experience the interactive features of the Services or the websites You visit through Us.

Storage, Processing and Retention of Personal Data

Personal Data collected by Kratos may be stored and/or processed in India where Kratos or its Service Providers maintain facilities. Kratos will also be entitled to use third-party service providers to store Your Personal Data. The storage location(s) are chosen to operate efficiently, improve performance, and create probability of errors for protecting Your Personal Data in the event of an outage or other problems. We take steps to ensure that the Personal Data We collect is processed according to the provisions of this Privacy Policy and the requirements of Data Protection Laws wherever the Personal Data is located.

Your Personal Data may be transferred to entities located overseas for processing and by using any part of the Services and or the Platform, You consent to the transfer, use and processing of Your Personal Data to such overseas entities which may have different laws governing Your Personal Data. However, the level of protection that will be applied to the transferred Personal Data will be at least comparable to the protection provided under this Privacy Policy.

We may retain Your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by Applicable Law.

We will cease to retain Your Personal Data or remove how the data can be associated with You as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected and is no longer necessary for legal or business purposes.

Your Rights

You are free to remove or delete content from Your User Account by logging in and visiting support in app or simply sending an email to support@kgen.io, subject to the Terms of Use, this Privacy Policy, and Applicable Law.

You may opt out of receiving marketing and promotional communications from Us. However, You will continue to receive necessary transactional emails until Your User Account is deleted.

Subject to the exceptions under Data Protection Laws, if You wish to make a request for access to a copy of the Personal Data which We hold about You or information about the ways in which We use or disclose Your Personal Data, or a correction request to correct or update any of Your Personal Data which We hold about You, You may submit Your request via email at contact@kgen.io. Please note that a reasonable fee may be charged for an access request. If so, We will inform You of such fee before processing Your request.

You may withdraw Your consent for the collection, use or disclosure of Personal Data by changing the relevant privacy settings on Your device or by a written request via email at contact@kgen.io. For some Personal Data, You may not have the ability to withdraw consent while your User Account is active. We shall inform You of the likely consequences of such withdrawal at the time of You making the request.

Third Party Links and Sites

The Services and/or the Platform may contain links to or information about third-party websites that are not within Our control. We are not responsible for the privacy practices of any external website or mobile application.

You agree that We are not liable in any manner, whatsoever, for any content as may be displayed on such third-party websites.

If You follow a link to any third-party websites or application, please note that We do not accept any responsibility or liability for the same. Please check the relevant policies before You submit any information to these websites, mobile applications, or their affiliates.

Grievance Redressal Officer

You may contact Our Grievance Redressal Officer if You have any enquiries or feedback on Our personal data protection policies and procedures, or if You wish to make any request, by email at contact@kgen.io.

For any other questions relating to this Privacy Policy, or if You believe that the Platform has not adhered to this Privacy Policy, You can write to Us at: contact@kgen.io.

Changes to this Privacy Policy

We reserve the absolute and unconditional right to update, modify, delete, or otherwise make changes to this Privacy Policy at any time. Any changes to this Privacy Policy will be posted to the Platform. A notification may be sent to Your registered email address.

You can determine when this Privacy Policy was last modified by referring to the “Last updated on” legend at the beginning of this Privacy Policy. It shall be Your responsibility to check this Privacy Policy periodically for changes.

Any changes to this Privacy Policy will take effect and be binding on You from the time of posting the changes to the Platform. If You continue to use any Services following any changes to this Privacy Policy, You will be deemed to have accepted the changes and the updated version of this Privacy Policy.

If You do not agree with the changes, please refrain from using the Platform. It is Your responsibility to review this Privacy Policy (and the applicable conditions) from time to time.

If any provision of this Privacy Policy shall be held to be invalid, illegal, or unenforceable for any reason whatsoever, the validity, illegality, and enforceability of the remaining provision of this Privacy Policy shall not in any way be affected or impaired thereby.