**PRIVACY POLICY** **Last updated on: 12 August, 2026** 1. **Introduction and Scope** This Privacy Policy (the “**Policy**”) applies to the processing of personal data carried out in connection with the operation of the website [www.digitain.com](https://www.digitain.com/) (the “**Website**”) and the provision of related online services (the “**Services**”). For the purposes of the Website and related Services, Digitain LLC, a company duly incorporated and existing under the laws of the Republic of Armenia, registered under registration number 286.110.811416, with its registered address at 15/3 Isakov av., Yerevan, 0082, Republic of Armenia (“**Digitain LLC**”), is responsible for the collection and processing of Personal Data obtained through the Website and related Services. The Website is operated by Digitain (MT) Limited, a company duly incorporated and existing under the laws of Malta, registered under company number C 87254, with its registered office at Tower Business Centre, 2nd Floor, Office 230, Triq it-Torri, Swatar, Birkirkara, BKR 4013, Malta (“**Digitain MT**”). Depending on the relevant processing activity, Digitain LLC and Digitain MT (together hereinafter also referred to as “**Digitain**”) may act as independent or joint controllers, or one entity may process Personal Data on behalf of the other as a processor. The respective roles and responsibilities of the relevant entities will depend on the specific processing activity and applicable legal and contractual arrangements. For the operation of the Website, Digitain MT operates and maintains the Website, while Digitain LLC collects and processes Personal Data submitted through or otherwise collected via the Website for the purposes described in this Policy. Where Digitain MT determines the purposes and means of any processing carried out in connection with the Website, Digitain MT may act as a joint controller with Digitain LLC for such processing. References in this Policy to “**Digitain**”, “**we**”, “**us**”, or “**our**” mean Digitain LLC and/or Digitain MT, as applicable to the relevant processing activity. Where necessary, the identity of the relevant controller or joint controllers, together with their respective contact details and applicable responsibilities, will be specified in the relevant section of this Policy or in the applicable notice, form, platform, contract, or other communication through which Personal Data is collected. Nothing in this Policy limits or excludes any rights available to individuals under applicable data protection laws. References to “you” in this Policy include any individual whose Personal Data we process in connection with our business activities and Services. This may include prospective customers, customers, suppliers, business partners, visitors to the Website, and representatives of organizations that interact with us. In particular, where our customer, supplier, or business partner is a legal entity, “you” may include its directors, officers, shareholders, ultimate beneficial owners, employees, authorized users, representatives, agents, and other individuals whose Personal Data is provided to us or otherwise processed in connection with the establishment, management, or performance of the relevant business relationship. Digitain LLC and Digitain MT are committed to protecting the privacy and Personal Data of individuals who access or use the Website and Services and to processing Personal Data in accordance with applicable data protection laws. This Privacy Policy explains how we collect, use, process, disclose, store, and protect any information that you share with us (hereinafter “**Personal Data**” as further defined below), and describes the rights available to data subjects under applicable data protection laws. Where Personal Data of individuals located in the European Economic Area (“**EEA”**), the United Kingdom, or Switzerland is processed, Digitain LLC and/or Digitain MT processes such data in accordance with Regulation (EU) 2016/679 (GDPR), the UK GDPR, and applicable national implementing laws, to the extent such laws apply to the relevant processing activity. This Policy is designed to apply across multiple jurisdictions and is supplemented where required by mandatory local law. By using our Website and/or Services, you acknowledge that you have read and understood this Policy. Any amendments to this Policy will be displayed at the Website and will be considered as valid promptly after the date of publication. You should check this page occasionally to make sure you are comfortable with any changes to the Policy. **2\. Definitions** **Controller:** the natural or legal person which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data. **Processor:** a natural or legal person which processes Personal Data on behalf of the Controller. **Joint Controllers:** two or more Controllers which jointly determine the purposes and means of the Processing of Personal Data. **Personal Data**: any information that can be used to uniquely identify a single person, either directly or indirectly.. **Processing**: any operation performed on Personal Data (e.g. collection, storage, use, disclosure). **Data Subject**: an identified or identifiable individual whose Personal Data is processed. **3\. Data Controller and Contact Details** For the purposes of the Website and related Services, the relevant data controllers are: **Digitain LLC** Legal name: Digitain LLC Registration number: 286.110.811416 Registered address: 15/3 Isakov av., Yerevan, 0082, Republic of Armenia **Digitain (MT) Limited** Legal name: Digitain (MT) Limited Registration number: C 87254 Registered address: Tower Business Centre, 2nd Floor, Office 230, Triq it-Torri, Swatar, Birkirkara, BKR 4013, Malta Digitain LLC and Digitain MT may act as joint controllers in respect of certain processing activities relating to the Website and Services, while in other circumstances one entity may act as a processor on behalf of the other. Their respective roles will depend on the nature and purpose of the relevant processing activity and applicable legal and contractual arrangements. The identity of the relevant data controller(s), and their respective roles where applicable, will be made available at the time of data collection and may also be specified in the applicable contracts, terms and conditions, privacy notices, legal notices, forms, or other communications.For any questions regarding the processing of personal data or the exercise of your data protection rights, you may contact us at: **Email address**: [info@digitain.com](mailto:info@digitain.com) **Postal address**: 15/3 Isakov av., Yerevan, 0082, Republic of Armenia Where Digitain LLC and Digitain MT act as Joint Controllers, Data Subjects may exercise their rights in relation to and against each Joint Controller in accordance with applicable data protection law. **4\. Collecting Your Personal Data** We collect the following information through the following means: **4.1. Information you give us** We receive and store personal data that you provide to us directly, including when you or the organization you represent enquire about, apply for, access, or use our Services, register for an account, communicate with us by email, telephone, through our websites, portals, or other electronic means, participate in meetings, events, or business discussions, or otherwise interact with us in the course of a business relationship. This information may include contact details, professional information, account credentials, correspondence, and any other information provided in connection with the Services. **4.2. Information we collect about you automatically** We automatically collect certain information when you access or use our websites, platforms, portals, or Services. Such information may include IP addresses, device identifiers, browser type, operating system, usage data, log files, cookies and similar technologies, and information regarding how our Services are accessed and used. Collecting this information helps us understand how visitors and customers interact with our Services, improve user experience, maintain system security, troubleshoot technical issues, monitor performance, conduct analytics, and enhance the functionality and effectiveness of our Services. We may also process such information to comply with legal and regulatory obligations and for fraud prevention, risk management, information security, and compliance purposes. **4.3. Information from Other Sources** We may receive personal data from third parties, publicly available sources, business partners, service providers, regulatory authorities, and commercial databases. We may combine such information with information already held by us where permitted by applicable law. Prior to establishing a business relationship and on an ongoing basis where required, we may conduct due diligence and compliance checks relating to prospective and existing customers, suppliers, partners, and their representatives, directors, shareholders, ultimate beneficial owners, and other relevant individuals. Such checks may include identity verification, sanctions screening, politically exposed person (PEP) screening, adverse media screening, anti-money laundering (AML), counter-terrorist financing (CTF), and other compliance-related assessments required by applicable laws, regulations, industry standards, or our legitimate business interests in managing legal, regulatory, and reputational risk. Where Personal Data has not been obtained directly from you, we will provide the information required under applicable data protection laws, unless an exemption applies, for example where you already have the information, where providing it would be impossible or involve disproportionate effort, or where the collection or disclosure is expressly required by law. **5\. Categories of Personal Data We Collect** Depending on how you interact with our Services, we may collect the following categories of Personal Data: **5.1. Identification and Contact Data** First and last name Username and account credentials Email address Telephone or mobile number Postal address (street, city, postal code, country) **5.2. Technical and Usage Data** IP address Approximate location (city, country) Device type, operating system, browser type Log files, access times, pages viewed, clicks, and navigation data **5.3. Communications Data** Emails, calls, messages, and other communications with us or our representatives or us We only collect Personal Data that is necessary, relevant, and proportionate for the purposes described in this Policy. **5.4. Professional and Business Relationship Data** Job title, role, department, employer or organization name Authority to represent a company or organization Business contact details Contractual records, order forms, commercial correspondence and meeting records Shareholder, director, officer, representative, agent, authorized user or ultimate beneficial owner information, where relevant to the business relationship **5.5. Marketing and Preference Data** Newsletter subscriptions Event registration and participation information Marketing preferences and consent records Records of opt-outs, objections and unsubscribe requests Interactions with marketing communications **5.6. Compliance and Due Diligence Data** Identity verification information Sanctions, PEP, AML, CTF and adverse media screening results Fraud prevention and risk assessment data Information required to comply with legal, regulatory, tax, accounting, audit, or contractual obligations **6\. Purposes of Processing** We process Personal Data for the following purposes: * Providing, operating, and maintaining the Services * Creating and managing user accountsProcessing payments and managing commercial transactions relating to the Services * Customer support and communications * Compliance with legal and regulatory obligations (including gambling, AML, tax, and accounting laws) * Fraud prevention, security monitoring, and risk management * Improving, testing, and analysing the performance of our Services * Sending service-related notifications * Sending marketing communications where permitted by law and subject to your preferences In addition to the purposes described above, we may process your Personal Data where necessary to comply with applicable laws, regulations, legal obligations, or requests from competent authorities. We may also use your email address to provide information about our Services, including updates, improvements, news, events, and other relevant communications. You may opt out of receiving such communications at any time by contacting us and requesting that these notifications no longer be sent. Please note that you cannot opt out of communications that are necessary for the provision of the Services, including mandatory notices relating to the Services, security matters, changes to this Policy or other policies, planned maintenance, suspension, or discontinuation of the Services. **7\. Legal Bases for Processing** We rely on one or more of the following legal bases: * **Performance of a contract**: processing necessary to provide the Services and perform contractual obligations * **Legal obligation**: processing required to comply with applicable laws and regulatory requirements * **Legitimate interests**: processing necessary for fraud prevention, security, analytics, and business operations, provided such interests are not overridden by your fundamental rights and freedoms * **Consent**: where required by law (e.g. direct marketing, non-essential cookies) * **Public interest**: where processing is required under regulatory or supervisory frameworks

Purpose	Legal Basis
Customer onboarding	Contract
AML screening	Legal obligation
Website analytics	Legitimate interest or Consent
Marketing communications	Consent

Where processing is based on legitimate interests we assess and balance our interests against the rights and freedoms of affected individuals. **8\. Automated Decision-Making and Profiling** We may use automated systems, including profiling, to support fraud prevention, AML checks, transaction security, and risk management. Such processing is either: * necessary for entering into or performing a contract; or * authorised by applicable law; or * subject to appropriate safeguards, including the right to obtain human intervention. You have the right to request human review, express your point of view, and contest automated decisions, where such rights apply under applicable data protection laws. These systems may generate alerts, risk scores, recommendations, or indicators requiring further review. Unless expressly stated otherwise, decisions that produce legal effects or similarly significant effects are not made solely by automated means and are subject to appropriate human review. **9\. Cookies and Similar Technologies** We use cookies and similar technologies to ensure the proper functioning of our website, enhance user experience, analyse traffic, and support security and fraud prevention. 9.1. Cookies are small text files placed on your device when you visit a website. They allow the website to recognise your device and store certain information about your preferences or past actions. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. Most of the cookies we use are so-called “session cookies.” They are automatically deleted after your visit. Other cookies remain in your device’s memory until you delete them. These cookies make it possible to recognize your browser when you next visit the site. Cookies are categorised as: * Strictly necessary cookies (always active) * Analytics cookies * Functional cookies * Marketing cookies * Security cookies * Preference cookies Strictly necessary cookies are used without consent where they are required for the Website to function or to provide a service requested by you. Analytics, functional, marketing, social media and other non-essential cookies are used only where you have provided consent through our cookie banner or cookie preference center, unless applicable law permits another lawful basis. Non-essential cookies are placed only after obtaining your explicit consent via our cookie management tool. You may withdraw or modify your consent at any time through your browser settings or our cookie preference center, however, if you choose to decline cookies, you may not be able to fully use the Services or the Website. Further information is available in our dedicated Cookie Policy. **10\. Data Sharing and Recipients** We may share Personal Data with: * Digitain LLC and Digitain MT, where necessary for the relevant processing activities and in accordance with their respective roles as Controllers, Joint Controllers, or Processors; * Trusted service providers acting as processors (e.g. hosting, payment processing, identity verification, fraud prevention) * Professional advisers (legal, audit, compliance) * Regulators, supervisory authorities, law enforcement, or sports bodies where required by law or to prevent unlawful activity * Third parties in connection with a merger, acquisition, or sale of assets, subject to appropriate safeguards All processors are required to process Personal Data in accordance with applicable data protection requirements and, where required, under written agreements containing appropriate confidentiality and security obligations.**International Data Transfers** Personal Data may be transferred between Digitain LLC and Digitain MT and to service providers or other recipients located outside the EEA, the United Kingdom, or Switzerland, where necessary for the purposes described in this Policy. Where applicable data protection law requires safeguards for such transfers, we will rely on an appropriate lawful transfer mechanism, including an applicable adequacy decision, Standard Contractual Clauses, the UK International Data Transfer Agreement or Addendum, or other lawful transfer mechanism recognised under applicable law. **11\. Data Retention** Personal Data is retained only for as long as necessary for the purposes for which it was collected, including: * The duration of the contractual relationship * Mandatory retention periods under gambling, AML, tax, and accounting laws * The establishment, exercise, or defence of legal claims Retention periods vary depending on the data category and applicable legal requirements. We may retain Your personal data where such retention is necessary to comply with a legal obligation to which we are subject, or in order to protect Your legitimate interests or the vital interests of another natural person. We may also keep derivatives of Your information for analytics purposes where no automated decision-making is involved. **12\. Data Security** We implement appropriate technical and organisational measures to protect Personal Data from unauthorised access, unlawful processing, accidental loss, destruction and damage, including encryption, access controls, network security, and staff confidentiality obligations. Despite these measures, no system can be guaranteed to be completely secure. While we implement appropriate technical and organizational measures to protect your information, you also play an important role in maintaining its security. We encourage you to take reasonable steps to safeguard your personal information, both physically and electronically. Such measures may include: * Installing and regularly updating antivirus software; * Keeping operating systems, web browsers, and other applications up to date; * Protecting computers, mobile devices, and other devices with secure passwords or other authentication methods; * Using strong and unique passwords for online accounts; and * Taking other appropriate precautions to prevent unauthorized access to your information. If we become aware of a Personal Data breach, we will assess it and, where required by applicable law, notify the competent supervisory authority and/or affected individuals within the applicable legal time limits. **13\. Your Rights** Subject to applicable law, you have the following rights: * Right of access * Right to rectification * Right to erasure * Right to restriction of processing * Right to data portability * Right to object to processing based on legitimate interests or direct marketing * Right to withdraw consent at any time * Right not to be subject to decisions based solely on automated processing * Right to lodge a complaint with a competent data protection supervisory authority. Requests may be submitted to [management@digitain.com](mailto:management@digitain.com). We will respond within one month, subject to lawful extensions. You also have the right to lodge a complaint with your local data protection supervisory authority. **14\. Minors** Our Website and Services are intended for business users and are not directed at children. We do not knowingly collect Personal Data from children through the Website. If we become aware that we have collected Personal Data from a child without appropriate legal basis or required consent, we will take appropriate steps to delete such data. Where specific Services are subject to age restrictions under applicable gambling, gaming, betting, AML, consumer protection, or other laws, access to such Services is restricted accordingly. **15\. Withdrawal of Consent** Where the processing of your Personal Data is based on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing carried out before such withdrawal. You may withdraw your consent by adjusting your preferences in your account settings (where available), by using the cookie preference center for cookie-related consents, or by contacting us at [info@digitain.com](mailto:info@digitain.com). Please note that the withdrawal of consent may result in certain features or services no longer being available to you, where such processing is necessary to provide those features. Withdrawal of consent does not apply to processing that is required to comply with our legal or regulatory obligations, including obligations under gambling, anti-money laundering (AML), counter-terrorist financing (CTF), tax, or accounting laws, nor to processing necessary for the performance of a contract or based on our legitimate interests where permitted by law. **16\. Accountability** Digitain maintains records of processing activities, conducts data protection impact assessments where required, and regularly reviews its data protection compliance framework. **17\. Third-Party Websites** Our Services may contain links to third-party websites. We are not responsible for the privacy practices of such websites and encourage you to review their privacy policies before providing Personal Data. **18\. Changes to This Privacy Policy** We may update this Privacy Policy from time to time. Material changes will be notified via the website or other appropriate means. Continued use of the Services after the effective date constitutes acknowledgment of the updated Policy. Where required by applicable law, we will seek your consent before applying material changes to processing activities based on consent. The updated version of this Policy will indicate the date on which it was last updated.

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