PRIVACY
POLICY

This Privacy Policy ("Policy") describes how CK Holdings, Inc. ("ChessKings," "Company," "we," "us," or "our") collects, uses, stores, shares, and protects information obtained from users ("User," "Player," or "you") of the ChessKings mobile application, website, and related services (collectively, the "Platform"). By accessing or using the Platform, you acknowledge that you have read and understood this Policy and agree to the collection and use of your information as described herein.

This Policy is incorporated into and forms part of our Terms of Service. Capitalized terms not defined in this Policy have the meanings given to them in the Terms of Service.

1. INFORMATION WE COLLECT

1.1 Information You Provide Directly

We collect information you provide when you create an account, use the Platform, or communicate with us, including:

• Identity Information: Full legal name, date of birth, and government-issued identification information collected for age and identity verification.
• Contact Information: Email address, mailing address, and telephone number.
• Account Credentials: Username and password. Passwords are stored using industry-standard encryption and are never stored in plaintext.
• Payment Information: Credit card numbers, bank account information, and other financial data necessary to process deposits and withdrawals. Payment card data is processed by PCI-DSS compliant third-party payment processors. ChessKings does not store full payment card numbers.
• Tax Information: Social Security number, Tax Identification Number (TIN), or equivalent, as required by applicable law for winnings reporting.
• Communications: Messages, feedback, and support inquiries you submit to ChessKings.

1.2 Information Collected Automatically

When you access or use the Platform, we automatically collect the following:

• Device Information: Device type, operating system, device identifiers (such as device ID and advertising ID), and mobile carrier.
• Log Data: IP address, browser type, pages visited, referring URLs, access times, and crash reports.
• Gameplay Data: Contest participation history, game outcomes, move records, session duration, time-on-platform, and related gameplay metrics used to maintain contest integrity.
• Location Data: General geographic location derived from IP address. We do not collect precise GPS location unless you expressly grant permission.
• Connectivity Data: Network connection status and quality metrics relevant to contest integrity monitoring.

1.3 Information from Third Parties

We may receive information about you from:

• Payment processors and financial institutions, for verification and fraud prevention.
• Identity verification and KYC/AML compliance service providers.
• Analytics and advertising partners.
• Social media platforms, if you choose to connect a social account to your ChessKings profile.

1.4 Cookies and Similar Technologies

We use cookies, pixel tags, web beacons, and similar tracking technologies to maintain session state, analyze usage, and enhance your experience. You may configure your browser or device settings to reject cookies; however, this may limit certain Platform functionality. We do not currently respond to browser-level "Do Not Track" signals.

2. HOW WE USE YOUR INFORMATION

2.1 Platform Operations

• To create, maintain, and secure your account.
• To process entry fees, prize distributions, deposits, and withdrawals.
• To operate, administer, and facilitate contests.
• To verify your identity, age, and eligibility to participate.
• To enforce our Terms of Service, contest rules, and other policies.

2.2 Safety, Integrity, and Legal Compliance

• To detect, prevent, and investigate fraud, cheating, money laundering, and other prohibited conduct.
• To comply with applicable legal and regulatory obligations, including AML, KYC, and tax reporting.
• To respond to law enforcement requests and legal process as required by law.
• To protect the rights, property, and safety of ChessKings, our users, and the public.

2.3 Communications

• To send transactional communications, including account confirmations, contest results, and payment notifications.
• To send promotional and marketing communications, subject to your opt-out rights described in Section 5.
• To respond to support inquiries and user feedback.

2.4 Product Improvement and Analytics

• To analyze gameplay patterns and user behavior to improve Platform features and user experience.
• To conduct research and develop new features and services.
• To monitor Platform performance and diagnose technical issues.

3. HOW WE SHARE YOUR INFORMATION

ChessKings does not sell your personal information. We may share your information only in the following limited circumstances:

3.1 Service Providers

We share information with third-party vendors that perform services on our behalf, including payment processing, identity verification, fraud detection, cloud hosting, data analytics, customer support, and email delivery. These providers are contractually obligated to use your information only as directed by ChessKings and in compliance with applicable law.

3.2 Technology Partners

The Platform utilizes third-party technology partners to facilitate certain core features, including peer-to-peer wagering infrastructure. We share the minimum information necessary for these partners to perform their contracted functions, and these partners are bound by confidentiality and data protection obligations.

3.3 Legal Requirements

We may disclose your information to government or regulatory authorities, law enforcement, or other parties as required by applicable law, court order, or legal process, or where we reasonably believe disclosure is necessary to: (a) comply with a legal obligation; (b) protect the safety of ChessKings, users, or the public; (c) prevent or investigate fraud or illegal activity; or (d) enforce our Terms of Service.

3.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of ChessKings or substantially all of its assets, your information may be transferred to the successor entity. We will provide notice of any such transfer and advise you of any choices you may have.

3.5 With Your Consent

We may share your information with third parties with your express prior consent for purposes not otherwise described in this Policy.

4. DATA RETENTION

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to provide Platform services, comply with legal obligations, resolve disputes, and enforce our agreements. Retention periods include:

• Account information: retained for the duration of your account and up to seven (7) years following account closure, to comply with applicable tax and legal requirements.
• Gameplay and transaction records: retained for a minimum of five (5) years for compliance and fraud prevention.
• Communications and support records: retained for up to three (3) years.
• Marketing opt-out records: retained indefinitely to honor your preferences.

When information is no longer required, we delete or anonymize it in a secure manner consistent with applicable law.

5. YOUR PRIVACY RIGHTS AND CHOICES

5.1 Access and Correction

You may access and update certain account information through your account settings. To request correction of inaccurate information you cannot update directly, contact us at privacy@chesskings.com.

5.2 Deletion

You may request deletion of your personal information by contacting us at privacy@chesskings.com. We will honor deletion requests to the extent permitted by applicable law. Certain information may be retained for legal, compliance, or fraud prevention purposes notwithstanding a deletion request.

5.3 Marketing Opt-Out

You may opt out of marketing and promotional communications at any time by clicking "unsubscribe" in any marketing email or by contacting us at privacy@chesskings.com. You will continue to receive transactional and account-related communications regardless of marketing preferences.

5.4 California Privacy Rights (CCPA/CPRA)

California residents have the following rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA): (a) the right to know what personal information we collect, use, and disclose; (b) the right to request deletion of personal information; (c) the right to opt out of the sale or sharing of personal information; (d) the right to correct inaccurate personal information; and (e) the right not to be discriminated against for exercising these rights. ChessKings does not sell personal information as defined under the CCPA/CPRA. To submit a verifiable consumer request, contact us at privacy@chesskings.com.

6. DATA SECURITY

ChessKings implements industry-standard technical and organizational security measures designed to protect your personal information against unauthorized access, disclosure, alteration, and destruction. These measures include encryption of data in transit and at rest, role-based access controls, secure development practices, and regular security assessments.

No data transmission over the internet or electronic storage system is completely secure. While we take commercially reasonable steps to protect your information, we cannot guarantee absolute security. In the event of a data security breach that triggers statutory notification obligations, we will notify you and applicable regulatory authorities as required by applicable law.

7. CHILDREN'S PRIVACY

The Platform is not directed to individuals under the age of eighteen (18). ChessKings does not knowingly collect personal information from children under 18. If we learn that we have inadvertently collected information from a child under 18, we will promptly delete it. If you believe we have collected such information, please contact us immediately at privacy@chesskings.com. We are committed to compliance with the Children's Online Privacy Protection Act (COPPA) and all applicable children's privacy laws.

8. THIRD-PARTY LINKS AND SERVICES

The Platform may contain links to or integrations with third-party websites, services, or applications not owned or controlled by ChessKings. This Policy applies only to information collected by ChessKings through the Platform. ChessKings is not responsible for the privacy practices of third-party services, and we encourage you to review their respective privacy policies before providing them with any information.

9. CHANGES TO THIS PRIVACY POLICY

ChessKings reserves the right to update or modify this Policy at any time. When we make material changes, we will update the Effective Date at the top of this Policy and provide additional notice where appropriate, such as via in-app notification or email. Your continued use of the Platform following the effective date of any modification constitutes your acceptance of the updated Policy. If you do not agree to the updated Policy, you must discontinue use of the Platform.

10. CONTACT US

For questions, concerns, or requests related to this Privacy Policy or our data practices, please contact our Privacy Team at:

ChessKings Privacy Team

Email: privacy@chesskings.com

We will respond to verifiable requests within the timeframe required by applicable law, and in no event later than forty-five (45) days from receipt, subject to any permitted extensions.