Company: Aldex Win Ltd

Registration No: 16207

Jurisdiction: Autonomous Island of Anjouan, Union of Comoros

Effective Date: April 11, 2026

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1. GENERAL PROVISIONS

1.1. This Privacy Policy (hereinafter — the "Policy") outlines how Aldex Win Ltd (hereinafter — the "Company", "We", "Us") collects, processes, and protects the personal information of users (hereinafter — the "User", "You") of the platform.

1.2. The Company acts as a Data Controller under the laws of the Autonomous Island of Anjouan and adheres to international best practices in data protection.

1.3. By registering an account on our platform, you provide your explicit consent to the processing of your data as described in this Policy.

2. TYPES OF DATA WE COLLECT

To provide high-quality services and ensure compliance with AML/KYC regulations, we collect the following categories of data:

• Identity Data: Full name, date of birth, gender, and nationality.
• Contact Data: Permanent residential address, email address, and telephone number.
• Verification Data (KYC): Scanned copies of government-issued IDs, passports, utility bills, and proof of wealth (where applicable).
• Technical Data: IP address, browser type and version, time zone setting, operating system, and unique device identifiers.
• Transaction Data: Details of deposits, withdrawals, and betting history (excluding full credit card numbers, which are processed by PCI-DSS compliant providers).
• Marketing Data: Your preferences in receiving marketing from us and your communication preferences.

3. LEGAL BASIS FOR PROCESSING

We process your data only when we have a legal basis to do so:

3.1. Contractual Necessity: To manage your account and provide gaming services.

3.2. Legal Obligation: To comply with the Betting and Gaming Act 2005 of Anjouan and Anti-Money Laundering (AML) laws.

3.3. Legitimate Interest: To prevent fraud, ensure network security, and improve our services.

3.4. Consent: For sending promotional offers and using non-essential cookies.

4. HOW WE USE YOUR INFORMATION

4.1. Account Setup: Verifying your identity and eligibility to gamble.

4.2. Financial Transactions: Processing payments and preventing unauthorized transactions.

4.3. Risk Management: Monitoring betting patterns to identify problem gambling or fraudulent activity.

4.4. Customer Support: Resolving technical issues and responding to inquiries.

4.5. Regulatory Compliance: Reporting to the Anjouan Offshore Authority if required by law.

5. DATA SHARING AND DISCLOSURE

5.1. The Company does not sell, rent, or trade your personal data to third parties for marketing purposes.

5.2. We may disclose your data to:

• Game Providers: To facilitate the gameplay.
• Payment Processors: To execute financial transactions.
• Regulatory & Law Enforcement Bodies: When legally mandated under the laws of Anjouan or international treaties.
• Audit & Legal Advisors: To maintain corporate transparency and defend legal claims.
  5.3. All third-party providers are contractually obligated to protect your data and process it only under our instructions.

6. DATA RETENTION

6.1. We retain your personal data for as long as your account is active.

6.2. Post-Termination Retention: Following the closure of your account, we are required by AML regulations of Anjouan to store your Identity and Transaction data for a period of minimum 5 (five) years.

6.3. After the retention period, data is securely deleted or anonymized.

7. INTERNATIONAL DATA TRANSFERS

7.1. As a global operator (Targeting LATAM and other regions), your data may be processed in servers located outside your country of residence.

7.2. We ensure that such transfers are protected by Standard Contractual Clauses (SCCs) to maintain the same level of protection as required by our home jurisdiction.

8. YOUR RIGHTS AS A DATA SUBJECT

You have the following rights regarding your personal information:

• Right to Access: Request a copy of the data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure ("Right to be Forgotten"): Request deletion of data, provided it is no longer required for legal compliance.
• Right to Withdraw Consent: You can opt-out of marketing communications at any time.
• Right to Data Portability: Request the transfer of your data to another service provider.

9. SECURITY MEASURES

9.1. We implement SSL encryption, firewalls, and strict access controls to prevent unauthorized access.

9.2. All staff members of Aldex Win Ltd undergo regular data protection training.

9.3. Despite our efforts, no method of transmission over the Internet is 100% secure; therefore, we cannot guarantee absolute security.

10. COOKIES AND TRACKING

10.1. We use cookies to remember your preferences and analyze site traffic.

10.2. Detailed information is available in our Cookies Policy. You can manage your cookie settings through your browser.

11. AMENDMENTS TO THIS POLICY

11.1. The Company reserves the right to update this Policy at any time.

11.2. Users will be notified of significant changes via email or a notification on the platform. Continued use of the platform after such changes constitutes acceptance of the new terms.

12. CONTACT INFORMATION

For any questions regarding your privacy or to exercise your rights, please contact our Data Protection Officer (DPO):

• Email: legal@aldex.win
• Address: Hamchako, Mutsamudu, Autonomous Island of Anjouan, Union of Comoros.

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