Privacy Policy

Effective date: November 10, 2025

OUR APPROACH TO PRIVACY

VOLTAPE INTERACTIVE TECHNOLOGY LIMITED ("Mahjong Solitaire: Real Cash", "We", " Our", or "Us") is committed to protecting and respecting your privacy. This privacy policy sets out how We collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") and information regarding our use of trackers and similar technologies.

VOLTAPE INTERACTIVE TECHNOLOGY LIMITED operates the Mahjong Solitaire: Real Cash application (the "Service").

This privacy policy applies to Our Service. Before accessing or using Our Service, please ensure that you have read and understood how We collect, store, use and disclose your personal information as described in this privacy policy.

We are the data controller of the personal information We hold about you. This means We determine and are responsible for how your personal information is used.

We are committed to protecting the privacy of our users and the personal information they provide to us.

1. COLLECTION AND USE OF PERSONAL INFORMATION

1.1 Voluntary collection - We collect personal information that you voluntarily submit directly to Us when you register and use Our Service. This can include information you provide to Us when you register for an account, fill in a form on Our Service, create or edit your user profile on Our Service, correspond with Us by phone, e-mail or otherwise, or subscribe to Our mailing lists, newsletters or other forms of marketing communications, respond to a survey, post comments in discussion groups, enter a promotion, or use some other feature of Our Service.

1.2 Voluntary collection required for the Service - We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Service, in particular, if you wish to credit your account/balance and/or withdraw all or part of your gains. If you choose not to provide such personal information, We may not be able to provide those parts of the Service to you or respond to your other requests.

1.3 Voluntary collection categories - Annex 1 sets out the categories of personal information We collect about you and how We use that information, as well as the legal basis on which We rely to process the personal information.

1.4 Automatic collection -We also automatically collect personal information indirectly about how you access and use Our Service and information about the device you use to access Our Service.

1.5 Automatic collection details - Annex 2 sets out the categories of personal information We collect about you automatically and how We use that information. Annex 2 also lists the legal basis on which We rely to process such personal information.

1.5 Combination of collections - We may link or combine the personal information We collect about you and the information We collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us.

1.6 Anonymization - We may anonymize and/or aggregate any of the personal information We collect (so that it does not directly identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving Our Service, and developing new products and features. We may also share such information with others.

1.7 Storage - We will store the personal information We collect about you for no longer than necessary for the purposes set out in Annex 1 and Annex 2, in accordance with our legal obligations and legitimate business interests. Please note that financial data may be kept for up to 10 years to comply with applicable anti-money laundering and counter-terrorism financing policies.

2. RECIPIENTS OF PERSONAL INFORMATION

2.1 Personal information sharing - In addition to the recipients listed in Appendix 1 and Appendix 2, We may also share your personal information with the following (as required in accordance with the uses set out in Appendices 1 and 2):

Service providers and advisors: We may share your personal information with third-party vendors and other service providers that perform services for us or on our behalf, which may include providing mailing, email, chat services, payment services, identification verification services, fraud prevention, web hosting, or providing analytic services;

Third parties through technology integrated with Our Service: We may collect certain personal information through software provided by our partners, such as third-party analytics services which We integrate into Our Service. This software may collect data that relates to tracking, installations, and downloads on the device you use by collecting mobile identifiers, such as the ID for Advertising for iOS (IDFA). These partners may have access to the personal information collected in this way in order to maintain this software and provide us with services, such as calculating usage analytics in relation to the Service;

Affiliates: Other companies owned by or under common ownership as ESPORT NEWCO SAS, including our subsidiaries (i.e., any organization We own or control) and our ultimate holding company (i.e., any organization that owns or controls us), and any subsidiaries it owns. These companies will use your personal information in the same way as We can under this Privacy Policy;

Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of our business;

Law enforcement, regulators, auditors, and other parties for legal reasons: We may share your personal information with third parties as required by law or if We reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Use; and/or (iii) exercise or protect the rights, property, or personal safety of VOLTAPE INTERACTIVE TECHNOLOGY LIMITED, its Affiliates, its ultimate holding company, its users or others.

3. STORAGE AND TRANSFER OF PERSONAL

INFORMATION

3.1 Security - We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change, or damage. These measures include notably encryption, access control, and back-ups.All personal information We collect will be stored on secure servers.

3.2 International Transfers of your Personal Information - The personal information We collect may be transferred to and stored in countries outside of the jurisdiction you are in where We and our third-party service providers have operations. If you are located in the European Union ("EU"), your personal information may be processed outside of the EU including in the United States.

In the instance of such a transfer, We ensure that either:

the personal information is transferred to countries recognized as offering an equivalent level of protection; and

the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this privacy policy.

4. MARKETING AND ADVERTISING

4.1 Marketing and advertising communications - From time to time We may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.

4.2 Communication channels - Most marketing messages We send will be by email or text message to your phone. For some marketing messages, We may use the personal information We collect about you to help us determine the most relevant marketing information to share with you.

4.3 Opt-out - If you receive unwanted marketing communication from us or one of our business partners, you can use the unsubscribe link included in such communications to opt out of receiving future messages. Note that you will continue to receive emails regarding the transactions of products or services you have requested. We may also send you certain non-promotional communications regarding Our Service, and you will not be able to opt out of those communications (e.g., communications regarding potential evolutions of Our Service or updates to our Terms or this Privacy Policy).

5. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL

INFORMATION

In accordance with applicable privacy law (in particular but not limited to General Data Protection Regulation for European users and California Consumer Privacy Act for Californian users), you have the following rights in respect of the personal information that We hold about you:

5.1 Consent withdrawal - You can withdraw your consent or refuse further data collection at any time. Please note that if VOLTAPE INTERACTIVE TECHNOLOGY LIMITED does not sell the personal information of its users, We may share it with third parties such as analytics and advertising companies in order to improve and personalize your experience and adapt the content and ads of Our Service. Withdrawing your consent will allow you to block the collection of data for these purposes and will de facto prevent the sharing of information with our analytics and/or advertising partners.

5.2 Right of access - You have the right to obtain:

confirmation of whether, and where, We are processing your personal information;

information about the categories of personal information We are processing, the purposes for which We process your personal information, and information as to how We determine applicable retention periods;

information about the categories of recipients with whom We may share your personal information; and

a copy of the personal information We hold about you.

5.3 Right of portability - You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

5.4 Right to rectification - You have the right to obtain rectification of any inaccurate or incomplete personal information We hold about you without undue delay.

5.5 Right to erasure - You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

5.6 Right to restriction - You have the right, in some circumstances, to require us to limit the purposes for which We process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

5.7 Right to objection - You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and We will assess and inform you if that is the case. You can object to marketing activities for any reason.

5.8 Right to opt-out - “Sale" means making personal information available to a third party for monetary or other valuable consideration, and “Share" means disclosing personal information to a third party for cross-context behavioral advertising, whether or not for monetary consideration. We do not sell your personal information for money. However, we may “Share" personal information — such as device identifiers, approximate location, and interaction data — with advertising and analytics partners to provide you with personalized advertising and measure the effectiveness of campaigns. You have the right to submit a request to opt-out of the Sale or Share of your Personal Data, and of our machine-based profile segmentation. After you opt-out, we may continue disclosing data to our partners to help us perform business-related functions such as, but not limited to, providing our Service, and ensuring that our Service is working correctly and securely.

5.9 Right to Limit Use of Sensitive Personal Information – You may request that we limit our use and disclosure of your sensitive personal information (such as precise geolocation, government ID documents, or financial account information) to purposes authorized by law.

5.10 Right to Non-Discrimination – We will not discriminate against you for exercising your rights. This means, for example, we will not deny you access to our Service, charge you a different price, or provide you a different level of quality solely because you exercised your rights.

5.11 Right exercice - If you wish to exercise one of these rights, please contact us at business@voltapegame.com

5.12 Response delay - We will seek to respond to any request relating to your rights within one month of receipt of such request.

Where, given the complexity of the claim or the number of requests received, the above deadline cannot be met, We will inform you of the extended deadline in which We will respond to your request. Such extension may not be more than two months from the date on which We notify you that an extension is required.

5.13 Abusive requests - We are entitled to object to requests which are clearly abusive in their number or in their repetition.

Where We do not follow up on your request, We will inform you within the one-month deadline of the grounds on which We have based our decision and of your right to refer a complaint to your national data protection authority.

6. LINKS TO THIRD PARTY SITES

Our Service may, from time to time, contain links to and from third-party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

7. OUR POLICY TOWARDS CHILDREN

Our Service is not directed at persons under 21 and We do not knowingly collect personal information from children under 21.

If you are located in the United States, please note: under the Children’s Online Privacy Protection Act (COPPA), we do not knowingly collect personal information from children under 13. Under the California Consumer Privacy Act (CCPA/CPRA), we do not sell or share personal information of users we know are under 16 without affirmative authorization.

If you are located in the European Union or United Kingdom, the Service is not available to children under 16, and we require parental consent for users under the applicable age of digital consent set by local law (between 13 and 16).

If we learn that we have collected personal information in violation of these rules, we will delete it and take steps to close the account. If you believe we may have collected personal information from a child, please contact us using the details below so that We can take steps to remove such information and terminate any account your child has created with us.

8. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time and so you should review this page periodically. When We change this Privacy Policy in a material way, We will update the Effective Date at the start of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page.

9. NOTICE TO YOU

If We need to provide you with information about something, whether for legal, marketing, or other business-related purposes, We will select what We believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Service. The fact that We may send notices to you will not stop you from being able to opt-out of certain types of contact as described in this privacy policy.

10. CONTACT

Email - If you have any questions or concerns about our Privacy Policy, please contact us at business@voltapegame.com

APPENDIX 1 – PERSONAL INFORMATION VOLUNTARILY SUBMITTED

Personal Information Category	Purpose	Legal Basis
Login and Profile information (incl. phone number, email, username, avatar)	We use your personal information to operate, maintain and provide to you the features and functionality of Our Service. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.	The legal bases for processing this data are the performance of our contractual obligations.
The processing is also necessary for our legitimate interests, in this case – keeping the integrity of our Service and the safety of our end-users.
Date of Birth	We use your Date of Birth in order to determine if you are eligible to use Our Service. Our Service is solely available for users above 21 years old. The processing is necessary for Our Service and also for Us to comply with Our legal obligations.	The legal bases for processing this data are the performance of our contractual obligations.
Precise and non-precise geolocation (incl. GPS position)	We will use geolocation in order to determine if you are in a country where our Service is available.	The legal basis for processing this data is compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are compliance with our legal obligations and assisting law enforcement agencies.
Financial information (incl. payment method details)	We use this information to process your purchases and transactions on our Service.
We use this information to identify and prevent fraud.	The legal bases for processing this data are the performance of our contractual obligations.
The processing is also necessary for our legitimate interests, namely the identification and prevention of fraud.
Emails, SMS, chat messages, comments, and opinions	We use this information for consumer services purposes to address your questions, issues and concerns. We use this information to develop existing products, create new products, improve our Service, as well as addressing your questions, issues and concerns.	The legal bases for processing this data are the performance of our contractual obligations.
The processing is also necessary for our legitimate interests, in this case – providing and improving our Service.
Marketing and Communications Preferences	We use this information to provide notifications, send news, alerts and marketing communications and in accordance with your choices.
We use this information to ensure that we comply with our legal obligation to send only those marketing communications to which you have consented.	The processing is necessary for our legitimate interest, namely ensuring the user receives the correct marketing and other communications in accordance with the user’s preferences.
The processing is necessary for compliance with a legal obligation to which we are subject.
Information about your use of our Service	We collect and analyse information about you and your usage of our Service to improve the usability and effectiveness of our Service, as well as addressing your questions, issues and concerns.
The processing is also necessary for our legitimate interests, in this case – providing and improving our Service.
All potential information and identity documents necessary to complete our Know Your Customers (KYC) and Anti-Money Laundering (AML) obligations (incl. identity document, selfie picture, proof of address)	We process your Personal Data in order to comply with our legal obligation under applicable laws.	The legal basis for processing this data is compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are compliance with our legal obligations and assisting law enforcement agencies.
The processing is also necessary for our legitimate interests, namely identifying and preventing fraud.

APPENDIX 2 – PERSONAL INFORMATION

AUTOMATICALLY COLLECTED

All the personal information listed below may be shared with the following third parties:

Advertising platforms to monitor our acquisition marketing campaigns;

Analytics solutions to track events on our platform;

Technical providers to manage authentication and perform fraud control.