SpreadMasters, Inc.

SpreadMasters 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 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 SpreadMasters 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 SpreadMaster'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.

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

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, Financial Account Data and Recruitment Process Data by: a) filling in a job application form on our Career Page, b) providing an email address to register with our websites and/or receive 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 via our registration and/or newsletters form. • Indirect interactions. You may give us your Personal Information indirectly by providing an email address and/or contact details to register with websites of and/or receive newsletters or other forms of communication from entities with whom we have an agreement to work in partnership with and provide services to ("Media Partners"). • Automated technologies. As you interact with our websites, we will automatically collect Usage Data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. Third parties or publicly available sources. We may partner with third parties (such as content providers and analytics companies including Google Analytics, OptInMonster, Hotjar, customer.io, plausible.io, segment.io, Mixpanel and Convert.com) to help us improve the services of our website, including to provide you with relevant and interesting content and to conduct analytics and measurement to understand how our services are used. These companies may collect information from you automatically in connection with your visit. We may use third-party Service Providers to automate the development process of our service (such as development platform to host and review code, manage projects, and build software, including GitHub). Generally, our websites can be accessed and used without registration and without having to provide us any Personal Data (Personal Information, Profile Data, and/or Recruitment Process Data). You may opt in to receive information about promotions, bonuses, bets, tips and strategy by subscribing to one or more of our mailing lists by providing your email address. You may any time opt out from receiving such communications by writing to us or clicking 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 that correspondence. We will not share your Personal Data with third parties for marketing purposes unless you have provided us with your express consent to do so and/or, with respect to our Media Partners, you have consented to receive marketing communications from those Media Partners. You may withdraw your consent by contacting those Media Partners directly. You may not withdraw your consent given to our Media Partners by contacting the Group Members.

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), including by sending you service-related emails or messages (e.g., messages regarding account verification, changes or updates to the functionality of our services, technical and security notices and alerts, notices about your subscription, including expiration and renewal 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 already purchased 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 have availed 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, to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics. Complying with law We use your Personal Data as we believe necessary and appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities. Compliance, fraud prevention and safety We use your Personal Data as we believe necessary or appropriate to (a) enforce the terms and 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 your Personal Data in certain contexts, such as when we would like to send you certain marketing messages. If we request your consent to use your Personal Data, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us. If you have consented to receive marketing communications from our third-party partners, including our Media Partners, you may withdraw your consent by contacting those partners directly (and not by contacting us). To create anonymous data We may create anonymous data from your Personal Data and other individuals whose Personal Data we collect. We make Personal Data into anonymous data by excluding information that makes the data personally identifiable to you and use that anonymous data for our lawful business purposes.

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 third parties that provide customer support, that we engage to host, manage, maintain, and develop our websites, mobile applications, 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 with this Policy. These third parties are prohibited from using or disclosing your information for any other purpose. Participants in the transaction processing chain We may share your Personal Data with companies in the transaction processing chain in connection with processing a payment transaction, such as merchants, banks or other card issuers, card associations, debit network operators and their members. Business Transaction If SpreadMasters 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 other third-party business partners, in order to provide our services. When we carry out any sharing 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 the minimal amount of your information necessary. We will never sell your information to any other 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 a sufficient 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 SpreadMasters may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, 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 deter against fraudulent, harmful, unauthorized, unethical or illegal activity. SpreadMasters may also disclose Personal Data in connection with any complaint regarding your use of our sites, for example, in the event of a complaint or legal action arising from a comment or content posted.

SpreadMasters is incorporated in the Delaware and SpreadMasters operates globally, with primary offices in United States. The mailing address of our principal executive office is 22 Greenville St., St. Helier, Channel Island of Jersey JE4 8PX. Your personal data may be transferred to other locations outside of your state, province, country or other governmental 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 protective as those in your jurisdiction. If we make such a transfer, we will require that the recipients of your personal data provide data security and protection in accordance with applicable law; and we will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information. European users should read the important information provided below in Section 10 about transfer of personal data outside of your region / country.

We have put in place appropriate security measures which we believe reasonably prevents your 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 need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality. We have put in place commercially reasonable procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. As we seek to use reasonable physical, electronic, and procedural measures to safeguard Personal Data within our organization against loss, theft, and unauthorized use, disclosure, or modification, however, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we strive to protect your information, we cannot guarantee its security. We will process and store the relevant Personal Data for as long as it is necessary for the purposes set out in this Privacy Policy or required in order to fulfil our legal, contractual, or statutory obligations and/or for the establishment, exercise or defense of legal claims. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our services, or we are legally obligated to retain this data for longer time periods. If, during your use of our websites, you post comments, we will keep a record of your commenting history. Personal data collected from commenting will be kept for the lifetime of the article commented on.

In this section, we describe the rights and choices available to all users. Users who are located in Europe and Brazil should read additional information about their rights in paragraph 10 below; users who are located in California, Virginia and other US states should read additional information about their rights in the relevant paragraphs below; and users who are located in Australia, Canada and Mexico should read additional information in paragraphs 14, 15 and 16 respectively. Marketing communications You can ask us to stop sending you marketing messages at any time by contacting us or clicking on the opt-out link included in each marketing message. You may continue to receive 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. If you decide not to provide the requested information, in some circumstances we may be unable to provide services to you. For example, we may be unable to process your transaction. 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 SpreadMasters directly to request access to, modify or delete your information. We may not be able 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 data protection officer using the contact information below. A complaint must be made in writing. Please provide details about your concern or complaint so that we can investigate it. We will determine whether to take action in response to your complaint, which, if we do so, may include conducting internal discussions with relevant business representatives. We may contact you for additional details or clarification about your concern or complaint. We will contact you to inform you of our response to your complaint. You also may have a right to file a complaint with a national or local regulatory agency.

We may provide paid products and/or services. In that case, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as 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 secure handling 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 at: https://www.apple.com/legal/privacy/en-ww/ / https://support.apple.com/en-us/HT203027 Google Play In-App Payments: Their Privacy Policy can be viewed at: https://policies.google.com/privacy?hl=en&gl=us / https://payments.google.com/payments/apissecure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en Stripe: Their Privacy Policy can be viewed at: https://stripe.com/us/privacy Authorize.net: Their Privacy Policy can be viewed at: https://www.authorize.net/about-us/privacy/.

Cookies are small pieces of data served on your computer that remember what you enter while 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 enhance your user experience, for example, to show you the most relevant information when you return to our site. When we use cookies, pixels and similar technologies, we do not typically process any information that personally identifies a user. By using our websites, you are consenting to us using cookies. You can manage cookie usage, disable or delete cookies through your browser settings at any time. The help function in your preferred browser should provide you with the correct information. Like many other companies which offer online services to their clients/customers, we use services provided by Google, Meta, and other companies that use tracking technology. One purpose of these services is to provide interest-based ads that are optimized for effectiveness based on inferences about you. Your choices to adjust your preferences for interest-based advertising, and/or opting-out of use of your personal 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 instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org. • Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third-party cookies/trackers. • Platform opt-outs. The following advertising partners offer opt-out features that let you opt-out of the use of your information for interest-based advertising: o Google: https://adssettings.google.com o Facebook: https://www.facebook.com/about/ads o Criteo: https://www.criteo.com/privacy/disable-criteo-services-on-internet-browsers/ o Bounce Exchange: https://www.bouncex.com/privacy/your-ad-choices/

We may use remarketing services to advertise on third party websites to you after you visited our service. We and our third-party vendors use cookies to inform, optimise and serve 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 Google Display 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 Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

As we may make changes to this Policy from time to time, you can always find an up-to-date version of this Policy on our websites. This Policy was updated as of September 21, 2025.