Introduction

1. This Privacy Policy (hereinafter referred to as the “Policy”) sets forth the general rules of collection, processing, distribution, use and storage of Website user’s Personal data including any dispute concerning privacy under current General Data Protection Regulation (GDPR). The website www.betibet-gold.com ( "Website", “Company”, "We", "Us", "Our") is owned and operated by Dama N.V., a company registered and established under the laws of Curaçao, with registration number 152125 and registered address at Scharlooweg 39, Willemstad, Curaçao. Dama N.V. is licensed and regulated by Antillephone N.V. (license no. 8048/JAZ2020-013), a company incorporated in (hereinafter the “Company”, “Us”, “We”).

2. It is understood and presumed that by the fact of use of the Website and its services or by clicking “I‘m at least 18 years old and accept with Terms of use and Privacy policy” button the User gives Consent, that he/she/it has fully read, understood and accepted this Policy. If any User does not agree with this Policy in general or any part of it, such User should withhold from using the Website and its services.

2.1. Definitions

The following definitions and rules of interpretation apply in this Privacy policy: For the purposes of this Regulation:

‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

‘Restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;

‘Profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

Pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;

‘Controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

‘Processor’means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

‘Recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

‘Third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

‘Consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

‘Personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;

‘Genetic data’ means personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question;

‘Biometric data’ means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data;

‘Data concerning health’ means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;

‘Website’ means a group of interrelated websites owned and operated by Dama N.V., available in the Internet via address: www.betibet-gold.com ;

‘Cookie’ is a text file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. 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. For more information on managing cookies, please go to www.allaboutcookies.org, or visit www.youronlinechoices.com.

‘Sensitive personal information’ An information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

3.Modifications

This Privacy Policy may be modified, changed, supplemented, updated at any time with prior written notice from . Your continued use of the Website and its services after any amendments or alterations of this Privacy Policy without notification of shall constitute your consent hereto and acceptance hereof of an updated version of this Privacy Policy. At any case, the date of the most recent amendments and alterations will be indicated at the top of this web page. If the User does not agree to such revised terms of the Privacy Policy or Terms of Use he/she must stop using this Website and may withdraw from his/her obligations under this Privacy Policy.

4.Information about the data controller

The data controller of this Website is Dama N.V., a company incorporated in Curaçao at Zuikertuintjeweg Z/N (Zuikertuin Tower), Curacao. Contact details: [email protected]

5. Information about the data processor

The data processor of this Website is SUM AND SUBSTANCE LTD incorporated and registered in England with company number 09688671, whose registered office is at 80 Wood Ln, Central Working White City, London, United Kingdom, W12 0BZ Contact details: [email protected]

6. Information about the Data Protection Officer

The Data Protection Officer is: Dama N.V., a company incorporated in Curaçao at Zuikertuintjeweg Z/N (Zuikertuin Tower), Curacao, [email protected]. Any authorized person or regulatory body may, at any time, contact the Data Protection Officer directly with any request related to data protection.

7. Legal basis for the processing of personal data

All personal data of the data subject is processed in compliance with Art. 6(1) of GDPR and in pursuance of the controller’s obligation to receive consent of the data subject for specific processing operations with personal data.

8. Collection of personal data and information

8.1.The Website www.betibet-gold.com collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files.

8.2. The following information may be collected for general purposes:

I. the browser type and its version; II. the operating system used by the accessing system; III. the website from which an accessing system reaches the website; IV. the sub-websites; V. the date and time of access to the Internet site; VI. an Internet protocol address (IP address); VII. the Internet service provider of the accessing system; VIII. any other similar data and information that may be used in the event of attacks on our information technology systems.

8.3. When using these general data and information, the Dama N.V. does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the Dama N.V. analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

8.4. The following information can be collected for services purposes: Contact information, such as name, home address, and email address; Account information, such as username (first name, last name, nickname), gender and password;

Information related to your virtual wallets public addresses;

Financial information, such as bank account numbers, bank statement, and trading information;

Identity verification information, such as images of your government issued ID, passport, national ID card, or driving license; Residence verification information, such as Utility bill details (city, country) or similar information.

8.5. Processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data

for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation are prohibited.

9. Such rule will not apply if one of the following applies:

The data subject has given explicit consent to the processing of those personal data for one or more specified purposes, except where Union or Member State law provide that the prohibition may not be lifted by the data subject;

Processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject;

Processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;

Processing is carried out in the course of its legitimate activities with appropriate safeguards by a foundation, association or any other not-for-profit body with a political, philosophical, religious or trade union aim and on condition that the processing relates solely to the members or to former members of the body or to persons who have regular contact with it in connection with its purposes and that the personal data are not disclosed outside that body without the consent of the data subjects;

Processing relates to personal data which are manifestly made public by the data subject;

Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity; Processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject;

Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional;

Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of Union or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject, in particular professional secrecy; Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

10. Cookies policy

The internet pages of this Website use cookies for the following purposes:

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. For example, most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

Google Chrome;

Mozilla Firefox;

Opera;

Microsoft Internet Explorer;

Safari Desktop, Safari Mobile;

Microsoft Edge.

You also have act in the following ways:

Opting-Out As part of our commitment to fair information practices, allow you to opt out of the use of information about your activities on other websites to provide you with Interest-based advertising. You can opt out of Google Analytics by installing Google’s opt-out browser add-on, and out of interest-based Google ads using Google’s Ads Settings. Even if you opt out, you may still receive advertising. It just means that the advertising you see will not be customised for you.

Refusing Cookies We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place. You can limit the collection of your information by disabling cookies on your browser. You may also be able to modify your browser settings to require your permission each time a site attempts to set a cookie. However, our website(s) (and many other websites) rely on cookies to enable certain functionality. If you choose to disable cookies, some of the services available on our website may not work properly.

Non- Websites and Links Our websites may contain links to non- websites. We are not responsible for the practices of those third party websites. Where you access other websites from our sites using the links provided, the operators of these websites may use cookies in accordance with their own cookies policy, which may differ from ours. You should read their privacy and cookie policies carefully before you provide any personal information to them.

Caution regarding automatic Cookie Functionality Browsers such as Microsoft Internet Explorer allow you to store passwords and logon IDs so you do not need to re-enter this information each time you access a web site. strongly urges you NOT to use this functionality to prevent unauthorized use of your online banking access code(s). The user is notified that blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all or certain features on our website.

Information collected by registration on the website