Privacy Policy - Multi-Product

Effective Date: August 26, 2025

1. Introduction

Disrupt Labs, Inc. ("Company" or "We") values your privacy and is committed to safeguarding it through this Privacy Policy.

Disrupt Labs develops and publishes games through its platform Disrupt Arcade, and provides users access to skill-based competitive gameplay, tournaments, and entertainment features. This policy governs all information collected when using Disrupt Labs’ technology, including:

• Leaderboards – displaying Player scores for single or multiple game categories.
• Matchmaking – connecting real players for competition, which may include leaderboard functionality.
• Real Cash Tournaments – skill-based games and tournaments offering real-money entry and prize structures, which may include leaderboards and matchmaking.

Any game or experience that uses Disrupt Labs technology is referred to as an "App" in this policy. The Disrupt Labs software integrated into each game is referred to as the "Disrupt SDK".

This policy explains:

• What information we collect and how.
• How we use, protect, and disclose that information.

This Privacy Policy applies to:

• Data collected via the Disrupt SDK, Disrupt Arcade apps, our websites, and any communications or transactions related to them.

This policy does not apply to information collected by third parties. Those parties have their own privacy practices which we recommend you review before sharing information.

By downloading, registering for, or using a Disrupt Labs App or website, you agree to this Privacy Policy. If you do not agree, do not use our services. We may update this policy from time to time, and continued use of our apps after changes means you accept them.

2. Age Restrictions

We take age-based privacy seriously:

• Under 13: Users cannot upload avatars, change default usernames, or reuse usernames across sessions. These users will be placed in "Anonymous Mode" to prevent data collection.
• Under 18: Users may access Leaderboards and Matchmaking, but cannot access Real Cash Tournaments.

We do not knowingly collect personal data from children under 13. If we learn that we have, we will delete it immediately. If you believe a child under 13 or under 18 has accessed restricted features, contact us at info@disruptarcade.com.

3. Information We Collect and How

We collect information in three ways:

• Directly from you (e.g., registration, transactions).
• Automatically when you use our apps or websites.
• From integrated third-party services (e.g., payment processors).

A. Information You Provide to Us

• Personal Identifiers: Name, email, phone, birthdate.
• Profile Data: Username, avatar, posted scores, or other in-app content.
• Gameplay Data: Scores, rankings, and performance metrics.
• Financial Information: Payment details (credit/debit card, billing address, bank info) when making deposits or withdrawals.
• Identity Verification (for withdrawals): Government ID image, short verification video, IP address, device/browser details, location.
• Public Data: If you share content publicly in the app, it may be visible to others.

B. Automatic Information Collection

• Usage Data: Game history, scores, time spent, traffic data, device logs.
• Device Info: Device model, OS, IP address, browser type, mobile network details.
• Location: Real-time device location to ensure compliance with jurisdiction-based rules.
• Cookies: Used on our websites for analytics and experience optimization. See our Cookie Policy.

C. Third-Party Data Collection

Certain integrated services may collect data to support core features, such as:

• Payment processors
• Identity verification partners
• Cloud hosting providers

We require these partners to use your data only for the services they provide for us.

4. How We Use Your Information

• Enable gameplay, leaderboards, matchmaking, and tournaments.
• Process deposits, withdrawals, and transactions securely.
• Verify your identity for compliance and fraud prevention.
• Improve app functionality and user experience.
• Provide personalized gameplay (e.g., skill-based matchmaking).
• Notify you about updates, account activity, and security alerts.
• Maintain compliance with financial, tax, and legal requirements.
• Display in-app advertisements where applicable.

5. Disclosure of Your Information

We may share:

• Aggregated/anonymous data for analytics and reporting.
• Personal data with trusted partners for:
  • Payment processing
  • Compliance and fraud checks
  • Marketing (if you have not opted out)
• To comply with legal obligations.
• During mergers, acquisitions, or asset transfers.
• To enforce our Terms of Use.

6. Your Rights and Choices

• Access & Correction: Request copies or corrections of your data.
• Deletion: Request deletion of your data (subject to legal and anti-fraud exceptions).
• Opt-Out: You may opt out of marketing and data sharing by following instructions in the app or contacting info@disruptarcade.com.
• Location & Cookies: You can restrict these through device settings.

7. Data Security

We use industry-standard security measures like SSL encryption for financial transactions. However, no system is 100% secure. Protect your account credentials and never share your password.

8. Responsible Gaming Policy

At Disrupt Arcade, we promote healthy gaming:

• Self-Exclusion: Contact us to suspend or permanently close your account.
• Refunds: Remaining balances will be refunded (after verification).
• Resources: See the end of this policy for links to responsible gaming organizations.

9. Changes to This Policy

We may update this policy periodically. Updates will be posted here with a new “Last Updated” date. Continued use means acceptance of the new policy.

10. Contact Us

Questions? Email us: info@disruptarcade.com

Responsible Gaming Resources

• National Council on Problem Gambling – Call 1-800-GAMBLER