PRIVACY POLICY

BALI GAMES

BOCA GAMES

2 FEB 2024 (Version 1.0)

# 1. OVERVIEW

1.Here’s the revised text with the requested changes:

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**BOCA GAMES PTE. LTD.** is a company duly incorporated under the laws of Provincia de Panamá, with registered office at Costa del Este, MMG Tower, 23, Paseo del Mar and Pacific Avenues, Provincia de Panamá, 2G5F+72C Provincia de Panamá (“The Company”) that is associated with the Project.

2. The Company endeavors to protect the personal information the Users provide in the process of using the Company’s services (“The Service,” “The Platform”).

3. The Company displays this Privacy Policy in a place where the User can easily check within the Service, in order to notify how personal information of the subject is being processed and for what purposes.

4. Please carefully review this Privacy Policy as it outlines our approach to the processing of personal information. If you do not agree to this policy, refrain from using our service or signing up, and from participating in any Airdrop events.

5. Unless otherwise specified, the terms used in this Privacy Policy adhere to the definitions set forth in the PUZZLE CHAMPIONS AIRDROP TERMS AND CONDITIONS.

### 1. PURPOSE OF THE PRIVACY POLICY

6. The Company notifies Users of the details of collected personal information, usage, provision, the entrusted information, and the destroying method through the Privacy Policy.

7. The User has legal rights, including the right to personal data self-determination regarding their own personal information. This Privacy Policy guides the way to exercise the Users’ rights on personal information.

8. This Privacy Policy prevents the infringement of personal information and guides how to recover from any infringement incidents.

### 2. PURPOSE OF COLLECTION AND USE OF PERSONAL INFORMATION

9. The Company processes personal information for the following purposes:

1. **User Management and Service Operation**

- Use of membership service;

- User identification;

- Survey and analysis for demand on service;

- Identification and management of the Users;

- Measures for smooth service operation;

- Delivery of service notice.

2. **Airdrop Participants Selection and Eligibility Verification**

- Airdrop Participants selection and eligibility verification;

- Provision of goods or services (including airdrops).

3. **Marketing and Advertisement Purposes**

- Marketing and promotion announcements;

- Provision of up-to-date information such as the latest newsletters, updates, drops/events, airdrops related to the Company and its work;

- Provision of customized/personalized service.

4. **Resolve Inquiries or Complaints**

- Verification of complaining person, confirmation of the complaint (inquiries);

- Contact for investigation and notification;

- Notification for answers;

- Responding to inquiries.

5. **Provision of Materials in Accordance with Relevant Laws and Regulations**

- In accordance with the provisions of laws and regulations, or when there is a request from the investigation agency in accordance with the procedures and methods stipulated in the laws for the purpose of investigation.

10. Personal information is not used other than the purposes mentioned in the foregoing paragraph. If the purpose is changed, necessary measures shall be taken to obtain separate agreement.

The primary objective of the Airdrop event is to gather participant information for the purpose of disseminating marketing and promotional materials. This activity is conducted in exchange for complimentary participation in the event.

### 3. ITEMS OF PERSONAL INFORMATION COLLECTED, PURPOSE AND TERM OF COLLECTION AND USE

11. The Company collects the following items of personal information, and when the additional collection of personal information occurs in individual services, the items of personal information to be separately collected, the purpose of collection and use of personal information, the retention period of personal information, etc. shall be notified, and consent shall be obtained separately:

Collection Method

Purpose of Collection and Use

Items Collected and Used

When signing up for membership

Use of membership service, personal and user identification, identification of fraudulent users, user management, marketing

When signing up: - Email address, nickname, whether the user is under the age of 18 or not. When signing up using SNS or external platforms: - Google: Email address, nickname, whether the user is under the age of 18 or not. - Apple: Email address, nickname, whether the user is under the age of 18 or not. When verifying mobile phone number: - Phone number.

When connecting wallet

Display of Digital Assets through wallet linkage within the service, provision of services based on identified Digital Assets (including participation in events, airdrops)

- Wallet address, quantity of Digital Assets held in the wallet, whether the user is under the age of 18 or not.

When participating in Staking

Provision of airdrop services utilizing Staking rewards.

- User's Staking information (including wallet address, ID, Staking duration, details of rewards generated from Staking, and information about the Staking participated in).

When participating in an event (including airdrops)

Identification of participants and provision of goods or services (including airdrops).

When participating: - Wallet address, ID (e.g., email address, nickname), snapshot. - Whether the user is under the age of 18, the number of Mystery Marbles and points earned in the airdrop (including details such as the number of Mystery Marbles, times participated in Dare, profit earned from Dare, Staking score, number of Raffle Balls a user can win). The Company operates a leaderboard that reveals the rankings of users. This includes the number of Mystery Marbles and points earned in the airdrop, along with the user's wallet address (partially masked). When eligible: - (For shipping): Phone number, address. - (For tax processing): Name, local/foreigner status, country of residency, Resident Registration Number (or tax ID/foreign registration number/passport number), email, etc. Certain items may change, and users will be notified separately with consent obtained for personal information collection.

Optional

To verify and contact event participants for providing event information and for marketing purposes.

When linking to 'X': - X ID, X's Handle.

When using the customer center service

Handling complaints.

- ID, nickname, email address. - Contents of the complaint post. Additional personal information may be collected if necessary, depending on the nature of the complaint. Separate consent will be obtained for such collection and processing.

Connection to Service

Automatically generated and collected during service use and processing.

- Automatically collected information such as service usage history, access logs, cookies, IP information (IP address, access time), authentication records, suspension records, mobile device information (carrier, device, country), browser type, user settings, and records of unauthorized use.

| | | | |

|---|---|---|---|

|When signing up membership|Required|Use of membership service, personal and User identification, identification of fraudulent users, User management, Marketing|When signing up: Email address, nickname, whether the user is under the age of 18 or not, When signing up using SNS or external platforms Google: Email address, nickname, whether the user is under the age of 18 or not, Apple: Email address, nickname, whether the user is under the age of 18 or not, When verifying mobile-phone number: Phone number|

|When connecting wallet|Required|Display of Digital Assets through wallet linkage within the service Provision of services based on identified Digital Assets (including participation in events, airdrops)|Wallet address, quantity of Digital Assets held in the Wallet, whether the user is under the age of 18 or not.|

|When participating in Staking|Required|Provision of airdrop services utilizing Staking rewards.|User's Staking information (including wallet address, ID, Staking duration, details of rewards generated from Staking, and information about the Staking participated in)|

|When participating in an event (including airdrops)|Required|Identification of participants and provision of goods or services (including airdrops)|When participating: Wallet address, ID such as email address, nickname, snapshot whether the user is under the age of 18 or not, the number of Mystery Marbles and points earned in the airdrop (including the number of Mystery Marbles a user has, the number of times a user has participated in Dare, the profit earned from Dare, a user's Staking score, and the number of Raffle Balls a user can win). *The Company operates a leaderboard that reveals the rankings of users. It will display the number of Mystery Marbles and points earned in the airdrop (including the number of Mystery Marbles a user has, the number of times a user has participated in Dare, the profit earned from Dare, a user's Staking score, and the number of Raffle Balls a user can win), along with the user's wallet address, with a portion of the wallet address being masked. When eligible: (If shipping is required): Phone number, address (If required for tax processing): Name, Local or Foreigner, Country of Residency, Resident Registration Number (or tax identification number/ foreign registration number/passport number), email etc. *However, some of the above items may be subject to change, and we will notify the user separately and obtain their consent for personal information collection.|

|Optional|To verify and contact event participants in order to provide event information and for marketing purposes|When linking to ‘X’: X ID, X’s Handle|

|When using the customer center service|Required|Handling complaints|ID, nickname, email address Contents of the complaint post * Additional personal information may be collected and processed if necessary depending on the nature of the complaint. We will request and obtain separate consent for the collection and processing of such information.|

|Connection to Service|Required|Automatically generated and collected during service use and processing|We may automatically collect and store information such as service usage history, access logs, cookies, IP information (IP address, access time), authentication records, suspension records, mobile device information (mobile carrier information, device information, country information), browser type, user settings, and records of unauthorized use.|

12. The Company collects and retains personal information in the following ways.

1. Ways to collect personal information

1. When the User agrees to the collection of personal information and enters relevant information: when signing up for a service, when using the mobile phone identification service, etc.;

2. During customer service procedure: collection of personal information in processing complaints via email, etc.;

3. When the User participates in online and/or offline events(including airdrops): Website, application, written form, email address, phone, fax, applying for gifts and etc.;

4. When personal information is provided through affiliated services or groups;

5. Through operation of automatic personal information collection devices.

2. Grounds for Retention: processing and reporting on customer requests and sending operational reports.

3. Retention Period: The Company, in principle, retains personal information until retention is no longer necessary for legal or business purposes.

13. As a general principle, The Company does not collect sensitive information that may violate the privacy of users.

4. ENTRUSTMENT OF HANDLING PERSONAL INFORMATION

1. The Company will take reasonable steps to protect your personal data against unauthorized collection, use and/or disclosure. Subject to the provisions of any applicable law or regulations, your personal data may be collected, used and/or disclosed for any purposes listed in clause 2.3 (where applicable), to the following:

1. the Company’s staff;

2. researchers, agents, contractors or third party service providers who provide services to the Company;

3. our professional advisers such as auditors and lawyers;

4. relevant government regulators, statutory boards or authorities, or law enforcement agencies to comply with any laws, rules, guidelines,

5. regulations or schemes imposed by any governmental authority; and

any other party to whom you authorize us to disclose your personal data to.

2. When the entrusted parties or consignment work is changed, the Company will update such information in this privacy policy.

3. In order to provide the best service possible, the Company may engage a data intermediary to process and handle personal data on its behalf. In these cases, we will only work with recognized personal data management firms and shall enter into contracts with these data intermediaries to include provisions that clearly set out the data intermediaries’ responsibilities and obligations to ensure compliance with the Act.

5. PROVISION OF PERSONAL INFORMATION TO THE THIRD PARTY

1. The Company does not provide or disclose personal information to any third party without User’s consent or unless demanded by applicable laws and process the information within a scope expressed in this privacy policy.

2. However, the Company provides or disclose the personal information to third parties for the following circumstances.

1. When it is provided in a form that an individual is not identifiable for the purpose of drawing up statistics, academic research or market research;

2. When business alienation or merger etc. occurs (However, when transfer of User’s personal information is needed in this case, the Company notify Users on the fact of transfer and the Users can withdraw their agreement on the usage of personal information);

3. When the information subject or the legal representative is unable to express agreement, and when such agreement is necessary in order to protect the third parties from threat of life, body, and property;

4. Other cases regulated by the laws and regulations.

3. If it is necessary to provide personal information to a third party to provide various services and benefits, the Company will notify the user of the 'person to whom the personal information is provided, the purpose of the provision, the items of personal information to be provided, and the retention/use period of the person to whom the personal information is provided' and provide the personal information to the third party only to the minimum extent necessary after obtaining express and individual consent.

6. OVERSEAS TRANSFER OF PERSONAL INFORMATION

1. The Company will transfer your personal data to the entities outside Singapore and other overseas entity(ies) the Company will notify you from time to time.

2. The company complies with either Section 5 or Section 6 for each type of overseas transfer of personal information.

7. RIGHTS OF USERS AND LEGAL REPRESENTATIVES AND METHOD OF EXERCISING THEM

1. The Users and their legal representatives may at any exercise their own rights or on behalf of principal the principal. However, the User’s rights can be restricted according to the laws and regulation and the personal information regulated as items to be collected may be restricted to request for delete, suspension of process.

1. Request to view personal information;

2. Request to correct personal information;

3. Request to delete or suspension of process.

2. The ways to exercise of rights indicated in the foregoing paragraph is as follows. The Company shall take immediate measure on the User’s request. The User may send mail and email to the Company.

Contact(email-address): [help@boca.games]

3. The legal representatives of the User or agent that has been delegated may exercise of rights indicated in this paragraph. In this case, power of attorney must be submitted.

4. The Company confirms whether the requesting person is the User him or herself or a righteous agent.

8. RESTRICTIONS FOR MINORS

1. The company does not direct our services to minors under the age of Eighteen (18).

2. If a minor uses the Service with a method unknown to the Company (such as impersonation) and the Company unintentionally processes the minor's personal information, Users and their representatives may request the Company to delete the minor's personal information by contacting the Company using the contact information listed in Section 8. In this case, the Company may request supporting documents or other information to verify the status of the individual or their legal representatives.

9. DESTRUCTION OF PERSONAL INFORMATION

1. In principle, the Company destroys the information without delay after the purpose of collection and use of personal information is achieved. However, the information that has obtained the User’s separate agreement or is obliged to preserve certain information for certain period of time shall be separated with other information and be stored.

2. The destruction procedure and method are as follows :

1. Destruction Procedure: The information entered by the User for customer consultation, etc. is stored for a certain period of time and then destroyed according to the reasons for information protection according to the internal policy and other relevant laws and regulations (refer to the retention and use period) after the purpose is achieved. This personal information will not be used for any other purpose other than being retained unless it is required by law.

2. Destruction term: For the information the retention term has passed and when the purpose is achieved or the Service is closed etc. and such information becomes unnecessary, the information is destroyed after the end date of retention term.

3. Destruction Method

1. Personal information stored in electronic file format will be deleted using a technical method that cannot reproduce the record.

2. Personal information printed on paper is shredded with a shredder or destroyed through incineration.

10. PERSONAL INFORMATION PROCESSING DEPARTMENT

1. In order to protect user's personal information and handle complaints related to personal information, the Company has designated the relevant department as follows.

Department Name: [Customer Support]

Contact(email-address): [help@boca.games]

2. User can report any complaints related to personal information protection that occur while using the Company's services to the person in charge of personal information management or the department in charge. The Company will promptly and sufficiently respond to Users' reports.

3. The Company is not liable for the loss of data caused by unpredictable accident when the Company took all predictable and reasonable measure to prevent risks in the network security, including hacking using up to date technology.

11. MATTERS CONCERNING THE INSTALLATION AND OPERATION OF AUTOMATIC PERSONAL INFORMATION COLLECTION DEVICES AND THEIR REJECTION

1. The Company installs and operates a device that automatically collects personal information, such as 'cookies' and 'sessions' that store and find your information from time to time. Cookies are very small text files sent to your browser by the server used to operate the Company's website and are stored on your computer's hard disk.

1. Purpose of use of cookies, etc.: The Company uses cookies in order to provide personal customized service. When a User visits the website, the website server reads cookies stored on the User's device to maintain environment settings and customized services. Cookies help the User use the website easily and conveniently by finding out the User's preferences.

2. Rejection of cookies, etc.: User has an option for setting a cookie. a User may reject the storage of all cookies and delete all cookies However, when a User rejects the storage of a cookie, then the User may have some difficulties in using a service.

2. The Company collects Users’ ADID/IDFA. ADID/IDFA are each identifier for advertisers assigned by android and apple to an app User’s device.

1. Purpose of Collecting ADID/IDFA: In order to provide customized contents based on demographic features, Users' interest, taste and propensity, including Customized advertisement.

2. Ways to collect ADID/IDFA: It is automatically collected when the Users visit the Service.

3. Retention/Usage period of collected ADID/IDFA: until retention is no longer necessary for legal or business purposes.

4. Rejection of ADID/IDFA being collected

1. Android OS : “Settings” > "Google Settings" > "Ad" > Turn off “Ad Personalization”

2. IOS: “Settings” > “Protection of Personal Information” > “Apple Advertisement” > Turn off “Ad personalization”

12. LIABILITY ON CONNECTED SITES

The Company may provide links to other websites to Users. In this case, since the Company does not have the control over the other website, the Company is not liable for and does not guarantee the usefulness, whether it is correct or legal. Please check the privacy policy for the connected site because the Company has no relation with the connected site.

13. AMENDMENT TO THE PRIVACY POLICY

The Company may amend its Privacy Policy to reflect any legal or service changes and shall notify such amendment.

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