Your privacy is important to us. This Privacy Policy explains how and why we collect, use, share, transfer, and store Personal Information, and provides information about your rights according to the applicable data protection laws. This Privacy Policy governs Personal Information we collect from users ("you" or "your") who visit our website and use our applications and services ("Platform"). We may revise this Privacy Policy from time to time by posting the amended terms on all amended terms automatically take effect immediately upon posting. Your continued use after an updated Privacy Policy is posted, means that you accept and consent to all its revisions. For the purposes of this Privacy Policy, "Personal Information" means any data relating to an identified natural person, or one who can be identified directly or indirectly by way of linking data, using identifiers such as name, voice, picture, identification number, online identifier, geographic location, or one or more special features that express the physical, psychological, economic, cultural or social identity of such person. You provide your consent to our processing of your Personal Information in accordance with this Privacy Policy.

1. Who is responsible for data protection?

• For the purposes of applicable data protection law, the "controller" processing your Personal Information is: Smart Box Holding ("Smart Box", "We", "Us" or "Our").

2. Personal Info collection

• The type of information We collect from you is either personal to you, or is general in nature: • Personal Information: When you register on the Platform as a member, update your information, purchase any goods or services, take part in promotions or send emails to Us, you provide Us with information that We store and process. Such information may include your name, address, phone number, email address, credit and debit card information, purchase and transaction history, interests, your image, your gender, age, location, nationality and other similar information. • General Information: We also receive and/or automatically collect more general information from and about you as a result of your visits to, and use of, the Platform. This general information can include information such as your IP address, the date and time you access the Platform, length of time you spend on the Platform, your browsing history (recorded by the text and graphics files that compose that page), the Internet address of the website from which you linked directly to Our Platform, and other similar information.

3. Collection and usage of Personal Info

• The Personal Information We collect from you in the course of rendering Our services will be processed for the purposes set out below. • We collect your credit/debit card information to allow you to make purchases of goods / services on the Platform. All credit/debit cards details and Personal Information will NOT be stored, sold, shared, rented or leased to any third parties. • We collect your image and voice for the purposes of promoting you as the winner of any Prize Draws. • Most of the Platform can be used without giving Us any information. However, certain services may involve the collection of information from you. We use this information to provide you with a better service, and in particular to: keep internal records; improve Our products, services and the Platform; communicate with you if you have ordered, purchased or participated in anything on the Platform; contact you for market research purposes; and provide you with information about new opportunities, promotions, special offers and other information that We may feel is relevant to you. If you contact Us via the Platform, or via email to the contacts set out on the Platform, We may keep a record of that correspondence. • We collect general information to help Us make the Platform more useful to users (including to help Us assess content of interest to visitors), and for other purposes such as determining the Platform's technical design specifications and identifying system performance or problem areas, for tracking activity on the Platform, preparing reports, assessing trends, and otherwise monitoring the way in which the Platform is being used none of which would be in a way that personally identifies any users. • Some of the advertisements you see on the Platform are selected and delivered by third parties, such as ad networks, advertising agencies, advertisers, and audience segment providers. These third parties may collect information about you and your online activities, either on the Platform or on other websites, through cookies, web beacons, and other technologies in an effort to understand your interests and deliver to you advertisements that are tailored to your interests. Please remember that We do not have access to, or control over, the information these third parties may collect. The information practices of these third parties are not covered by this privacy policy and you should check the privacy policies of these third parties.

4. Non disclosure of personal info.

• You agree that We may share your Personal Information within Our group entities and subsidiaries (together the "Company"). We will not share, sell or rent your Personal Information in any manner to any third parties outside of Our Company except when We have your consent under this privacy policy; or if required to do so by law or any governing authority. For example, We may share your Personal Information with Our third party service providers, with brands for advertising and marketing purposes, and with third parties for data storage purposes, and within Our Company. • We may transfer the Personal Information you provide to Us to another country. For example, we may store your Personal Information in a data centre in France. When we transfer your Personal Information to another country, we will take all reasonable steps to ensure that your Personal Information is protected in accordance with this privacy policy and applicable data protection laws, including through using legally recognised data transfer mechanisms, such as appropriate standard contractual clauses where required.

5. Security

• Keeping your Personal Information secure and preventing unauthorized access is of utmost priority to Us, and We take all steps reasonably necessary to protect your Personal Information against any unauthorised access, use, alteration, disclosure or destruction. Whilst We have put in place physical, electronic and managerial procedures to secure and safeguard your Personal Information, We will not be held responsible for any unauthorised access by third parties and We cannot guarantee that the Personal Information provided by you or that is transmitted via the Platform or by e-mail is totally secure and safe. • We encourage you to keep any passwords you use confidential and to be careful to avoid "phishing" scams where someone may send you an electronic message that appears to be from Us asking for your Personal Information. We will not request your ID or password through electronic messages.

6. USE OF COOKIES

• Like many websites, the Platform uses cookies, which are files that store information on your hard drive. Cookies allow the Platform to identify account holders, track new users, record session information, and generally to optimise your experience. Most browsers accept cookies automatically but if you choose, you can disable the cookies from your browser. For online advertising campaigns, cookies are automatically deleted after one (1) month. • We recommend that you leave cookies "turned on" so that you can enjoy a better experience on the Platform. You may occasionally get cookies from companies advertising on Our behalf or on behalf of Our Company. We do not control these cookies, and these cookies are not subject to this Privacy Policy.

7. USE OF GOOGLE ANALYTICS

• Our Platform uses Google Analytics, a web analytics service of Google Inc. ("Google"). Google Analytics uses cookies and/or text files to analyze website traffic. Information generated by cookies with your details (including your IP address) is transferred to a Google server in the United States of America. Google processes this information to evaluate your use of the Platform, compile reports about the Platform's activity on Our behalf, and deliver other related services regarding website and Internet use. Google may also share this information with third parties insofar as this is necessary or if these third parties process the information on behalf of Google. • You may disable the cookies from your browser by adjusting your browser settings. However, in this scenario, you may not be able to make full use of all the functions available on the Platform. By using the Platform, you agree to Google's processing of the type of information discussed in this section in the manner contemplated in this Privacy Policy. Us, and Our respective suppliers, and any of Our shareholders, our Company, and any of Our and their officers, directors, managers, members, agents, and employees, are not liable for any direct, indirect, punitive, incidental, special, or consequential damages or loss (including, without limitation, incidental and consequential damages, lost profits, or damages resulting from lost data or business interruption) arising out of, or in way connected with, the use of the type of information discussed in this section.

8. Social Media features

• Facebook, Instagram and Google tracking pixels are used on the Platform. This means that third parties may use cookies, web beacons, and similar technologies to collect or receive information from the Platform and elsewhere on the internet and use that information to provide measurement services and targeted adverts. If you wish to opt out of the use of these tracking pixels, please adjust your browser settings.

9. Your Marketing Preferences

• You may choose to receive or not receive marketing communications from Us by indicating your preferences. • You can click "unsubscribe" in any marketing electronic communications We send you, or by sending Us an email to our customer support. • On the Platform, you can choose whether you wish to receive marketing communications from Us. • Any marketing by Us, or any third parties on Our behalf, will be conducted in accordance with applicable laws and include (where applicable) methods to allow you to express your preferences (including the possibility of being removed from Our advertising and marketing lists as set out above).

10. Your Rights.

• Where the processing of your Personal Information is subject to data protection laws, you have certain data subject rights. Depending on the applicable law, these include: • Access: you have the right to request information about how We process your Personal Information. • Rectification: you have the right to request the rectification of inaccurate Personal Information about you and for any incomplete Personal Information about you to be completed. • Transfer: you have the right to request a transfer of your Personal Information. • Erasure: you have the right to have your Personal Information erased. • Restriction: you have the right to restrict the processing of your Personal Information in some cases. • Objection: you have the right to object to processing in some circumstances, including for automated processing. • In addition to the above, you have the right to withdraw your consent to the processing of your Personal Information at any time. Such withdrawal has no effect on any processing of your Personal Information that has occurred prior to the withdrawal of your consent. • If you have any questions about the type of Personal Information We hold about you or wish to exercise any of your data subject rights, please send a written request to Customer Support.

11. How long do we keep your Personal Info?

• We will retain your Personal Information for the length of time needed to fulfil the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law.