Chumba Lite Privacy Policy

Version: 3.1

Date updated: March 26, 2025

At VGW, we are committed to maintaining transparency and protecting the privacy of our customers.

VGW operates the Chumba Lite website (the “Website”) and app that is available through the Apple App Store

and Google Play

on mobile devices, and any subdomains, subpages, successor sites or any application

accessible via our website or app (the “App”).

At VGW, we are committed to protecting and respecting your privacy and maintaining the confidence and trust

of our players. This privacy policy (“Privacy Policy

”) explains how VGW collects, uses, maintains and shares

information collected from the App.

We are committed to complying with obligations under all applicable global data privacy laws, including the

General Data Protection Regulation ("GDPR"), the California Consumer Privacy Act, the Virginia Consumer Data

Protection Act, the Canadian Personal Information Protection and Electronic Documents Act (and any provincial

substantially similar law as applicable) and the Australian Privacy Act 1988 (Cth).

1. DEFINITIONS

Aggregate Information means information about groups or categories of customers, which does not identify

and cannot reasonably be used to identify an individual customer.

Anonymous Information means information that does not directly or indirectly identify, and cannot reasonably

be used to identify, an individual. When anonymous information is directly or indirectly associated with personal

information, the resulting information is also treated as Personal Information.

Personal Information means any information about you, whether it is true or not, that can reasonably be used

to identify you, or otherwise make you identifiable.

VGW (including “VGW Holdings Limited”, “VGW Malta Limited”, “VGW Group”, “We”, “Us” or “Our”) means

VGW Holdings Limited and any applicable subsidiaries, including VGW Malta Limited, VGW GP Limited, VGW

Games Limited, VGW Administration Malta Limited, VGW US, Inc., VGW Luckyland Inc., VGW Holdings US Inc.,

and VGW Canada Inc., that forms the VGW Group and may collect, use, maintain and disclose information

collected from the App as applies to this Privacy Policy.

2. DATA CONTROLLER

The data controller responsible for processing data collected through your use of the App (including any data you

may provide through the App) is VGW Malta Limited having its registered address at Trident Park, Notabile

Gardens, No6 – Level 3, Central Business District, Mdina Road, Zone 2 Birkirkara CBD2010 Malta (the “Data

Controller”).

3. TYPE OF INFORMATION WE COLLECT

3.1. We collect three types of information (as defined in section 1, Definitions):

● Personal Information

● Anonymous Information

● Aggregated Information

Any other information that we receive and identify as your Personal Information will be treated as Personal

Information by VGW.

3.2. The types of Information we may process depends on the business context and the purposes for which it

was collected. It may include:

Contact Details, such as your first name and surname, email address, and mobile or other phone numbers.

Personal Information, such as gender, age, age range or your image, and account login details, including

your username, password and pictures associated with your profile.

Geolocation Information, including approximate location information provided by a mobile or other device

interacting with the App, or associated with your IP address, where we are permitted by law to process this

information.

Usage Data, which may include activity, technical and device information about your use of the App, such

as the content you view, the time and duration of your visit on the App, how often you use our services, how

you first heard about our App, your preferences and information about your interaction with the content

offered through the App, your hardware model, device type, other unique device identifiers, operating system

version, browser type and IP address, as well as information sent bilaterally or within a small group using

text message, live chat, post or other similar methods of communication.

Information we obtain from a third-party, such as a site or platform provider (including Facebook, Apple

and Google), about your use of or interest in our services.

4. HOW WE COLLECT YOUR INFORMATION

4.1. INFORMATION YOU PROVIDE TO US DIRECTLY

This includes information collected when you visit our mobile app, website, register, respond to a survey,

fill out a form, and in connection with other activities, services, features, or resources we make available on

our App.

We collect information from you by telephone, video or in correspondence (including email, live chat, mail,

text message or social media). All telephone or video calls between you and VGW Group representatives

may be recorded for training, quality control and compliance purposes and by continuing with any such call

you consent to it being recorded.

4.2. INFORMATION WE COLLECT AS YOU USE OUR SERVICES

We also collect information about your use of our products and services through a variety of technologies

that are present when you visit the App or use our applications on third-party sites or platforms (whether or

not you are logged in or registered) including tags and application program interfaces (“API”) (further

information is set out in section 5, Personal Information Collected via Technology). Analytics tools are

also used by us to collect information, including when you visit the App or use our applications or services

on third-party sites or platforms.

4.3. INFORMATION WE RECEIVE FROM THIRD PARTY SERVICES PROVIDERS

Finally, we also use trusted sources to update or supplement the information you have provided, or we have

collected, including in order to verify or validate information (for example, postal address, documentation

and names).

5. PERSONAL INFORMATION COLLECTED VIA TECHNOLOGY

5.1 We and our service providers and data processors use industry standard identifiers to provide an

enhanced experience.

5.2 These technologies allow us to record certain pieces of information whenever you visit or interact with the

App. Information may include, in part, browser type, operating system, device type, an estimate of your

geographic location associated with your IP address, the location of your mobile device, the page served,

the time, referring URLs and other information normally transmitted in HTTP requests.

5.3 This statistical data provides us with information about your use of the services, such as general

engagement with a page, the type of content on that page and how long you stay on that page. Usage

information is generally non-identifying but if VGW associates it with you as a specific and identifiable

person, VGW will treat it as Personal Information.

5.4 The following are examples of these types of technologies:

a) APIs. APIs work by allowing different types of software to communicate with each other. They make

life a lot easier for programmers and provide a better experience for end users.

b) Mobile device identifiers. When you download or access our products via a mobile device, we and

our service providers and data processors may receive information about your geolocation (based

on your IP address) and your mobile device including advertising identifiers, hardware type, your

operating system and your in-game activity. We may share the advertising identifier associated with

your mobile device or tablet (such as the Apple IDFA and Google Advertising ID) with advertisers.

We and our service providers and data processors may use this information to provide you with

tailored advertising and other content. When you download or access our games through your

mobile device, we may ask permission to track your activity. If you initially consent to tracking, you

may later disable that permission in your device settings or withdraw your consent. In addition, if

you do not want to receive third-party tailored advertisements, you may opt-out by adjusting the ad

tracking settings on your device (such as turning on “Limit Ad Tracking”) and reset the advertising

identifier on your device. Further, depending on your platform provider (such as Apple or Google),

you may be able to download apps such as the Digital Advertising Alliance’s “AppChoices” app to

provide you with control regarding the collection and use of your cross-app data for tailored

advertising. For more information on the advertising choice mechanisms, visit the NAI’s Mobile

Choices page here

c) Event tagging. Event tagging (including Facebook App Events) allows us to track actions that occur

in the App such as application installs. By tracking these events we can view analytics, measure ad

performance, and build audiences for ad targeting.

6. HOW WE USE COLLECTED INFORMATION

6.1. The Data Controller is responsible for and may use your information for the purposes described in this

of the Data Controller as a data processor for the purposes described in the Privacy Policy.

6.2. We use the information collected to operate the App and to provide our products and services, to respond

to your questions and to fulfil all applicable regulatory requirements.

6.3. There may be occasions where we collect and use your information for the following specific purposes:

To provide and

manage the services

you request

This includes, for example, processing your registration, setting up and

looking after your account.

To improve customer

service and our

services

Information you provide helps us respond to your customer service

requests more efficiently; we may use feedback you provide to improve

our products and services.

To personalize user

experience

We may use information which has been aggregated to understand how

our users as a group use the services and resources provided on the

App.

To contact you about

our services including

marketing

We may contact you by email, live chat, telephone, text message, mail

or social media for communications related to your use of our services

and products, including in connection with your accounts, offers and

information about our products and services, promotions and

competitions you choose to enter, online surveys, new features that you

are entitled to access, and other important information. Please see

section 8, Your Privacy Rights, for your opt-out rights.

To send important

notices to you

From time to time, we may send important notices to you, such as

communications about purchases you have made, or legal notices

regarding the changes to our terms and conditions or other policies.

This information is important to your interactions with us, and you

acknowledge that you may not opt-out of receiving these

communications.

To comply with our

legal and regulatory

obligations

We may use information we collect about you to assess your social

gameplay activity for responsible social gaming purposes, or to comply

with any other legal or regulatory obligations (including the detection,

investigation and prevention of activity that violates our

Terms and

Conditions or that may be illegal).

To offer alternative

dispute resolution

services

We may provide information we collect about you to our service provider

for the specific purpose of resolving any disputes that have not been

satisfactorily resolved through our internal processes.

To conduct market

research and analysis

We may use information we collect about you to analyze how you

interact with our products and services, to monitor and analyze usage

and activity trends, and for other research, analytical and statistical

purposes.

6.4. BEHAVIORAL ADVERTISING

We may partner with a third-party service provider to: (a) display advertising on the App or any application

or website accessible via the App; and (b) manage our advertising on other websites (for example, using

custom audiences on Facebook) to help us provide more relevant advertisements.

Under some US state privacy laws, consumers have the right to opt out of the sharing or sale of their

Personal Information with third parties for targeted advertising (also known as behavioral advertising).

“Behavioral advertising” in this context means advertisements that may be sent to you based on your data

through the use of technologies to gather information about your activities on the App and other

applications and websites.

If you wish to opt-out of interest-based advertising click here (or if located in the European Union click here

or Canada click here). Please note you will continue to receive generic advertisements.

7. HOW WE SHARE INFORMATION

7.1. The following categories of data may be shared for behavioral advertising purposes:

a) Name and contact data;

b) Demographic data;

c) Subscription and licensing data; and

d) Interactions.

7.2. The above data may be shared with third parties that perform online advertising services for VGW for the

purposes of delivering tailored advertising based on your interests.

7.3. If you do not want to receive third-party tailored ads, you may opt-out by adjusting the ad tracking settings

on your device (such as turning on “Limit Ad Tracking”). You can also reset the advertising identifier (like

an IDFA) from your device’s settings, which will prevent continued use of existing behavioral data tied to

the previous advertising identifier. Depending on your platform provider (such as Apple or Google), you

may be able to download apps such as the Digital Advertising Alliance’s “AppChoices” app, that offers to

provide you with control regarding the collection and use of cross-app data for tailored advertising. These

opt-out tools are provided by third parties, not VGW. VGW does not control or operate these tools or the

choices that advertisers and others provide through these tools.

8. YOUR PRIVACY RIGHTS

8.1. We appreciate that by law and subject to certain conditions, you have a number of rights concerning the

Personal Information we hold about you. Further information and advice about your rights can be obtained

from the data protection regulator in your country or state.

8.2. Your rights may include, but are not limited to, the following:

The right to access

You have the right to access your Personal Information we

process, and certain other information (similar to that provided in

this Privacy Policy).

The right to rectification or

correction

You are entitled to your Personal Information corrected if it is

inaccurate or incomplete. You can request that we rectify any

errors in information that we hold about you.

The right to be informed

You have the right to know how we collect and use your

information and your rights regarding your Personal Information.

The right to object to

processing

You have the right to object to certain types of processing,

including processing for direct marketing and advertising.

The right to delete

You have the right to request the deletion or removal of your

Personal Information subject to certain exceptions. Please refer to

section 8.5, How to access or delete your information, for more

details.

The right to data portability

With certain exceptions, you have the right to obtain and reuse

your information in an easily understandable format. Please refer to

section 8.5, How to access or delete your information, for more

details.

The right to opt-out of

sharing

You have the right to opt out of the sharing of your Personal

Information to a third party for cross-context behavioral advertising.

The right to complain to a

supervisory authority

You also have the right to complain to the relevant data protection

supervisory authority about VGW’s processing of your Personal

Information. Please complete the Chumba Support Request Form

here or alternatively, email dataprivacy@vgw.co

The right to withdraw your

consent

If you are a resident of the European Economic Area or United

Kingdom and have given your consent for a particular processing

operation, you can withdraw it at all times by contacting

dataprivacy@vgw.co.

The right to lodge a

complaint with a data

protection authority

If you are a resident of the European Economic Area or United

Kingdom, you have the right to lodge a complaint with a data

protection authority.

8.3. ADDITIONAL RIGHTS TO US RESIDENTS

Residents of California have the right to: (1) request to know more about the categories and specific pieces

of Personal Information we collect, use and disclose; (2) request deletion of your Personal Information; (3)

opt out of sale of your Personal Information (if any); (4) not be discriminated against for exercising these

rights; and (5) limit use of your sensitive Personal Information if we use such Personal Information to infer

characteristics about you. We do not currently use sensitive Personal Information for such purposes. In

some states, we may be required to obtain your consent before collecting your sensitive Personal

Information.

Under some US state privacy laws, consumers have the right to opt out of the sharing or sale of their

Personal Information with third parties for targeted advertising (behavioral advertising). Please refer to

section 6.4 above for more details.

If you want to stop receiving promotional communications from us, you can click on the “unsubscribe” link

in any promotional email received from us.

8.4. HOW TO EXERCISE YOUR RIGHTS

You can exercise any of these rights by completing the Chumba Support Request Form here

alternatively, email dataprivacy@vgw.co. We will not discriminate against you (e.g., through denying

products and services or providing a different level of quality of goods or services) for exercising any of the

rights afforded to you.

You may opt-out of receiving commercial messages from us by following the instructions contained in

those messages or by contacting Customer Support

. In the event of your objection to processing for the

purpose of direct advertising, we will no longer process your Personal Information for these purposes.

If you would like to use an agent authorized in accordance with applicable law to exercise your rights, we

may request evidence that you have provided such agent with power of attorney or that the agent

otherwise has valid written authority to exercise those rights on your behalf.

8.5. HOW TO ACCESS OR DELETE YOUR INFORMATION

You have the right to view, manage, download and delete your information under the applicable privacy

laws, as set out in further detail in the table below. To exercise your rights, please submit the Chumba

Customer Request Form here or contact dataprivacy@vgw.co

Access your

information

You can access the following information from your use of our App and/or

interactions with VGW:

(a) Your activity within our App, including any games you’ve played.

(b) Personal Information that you’ve provided when you set up your

account in the App.

including things such as your location and game play history.

(d) Security and login information related to your account.

(e) Apps and websites from service providers and data processors

such as Facebook, Apple and Google through your use of the App.

(f) Information related to your activity with advertisements that interact

with our App.

Download your

information

You are able to download your information from your use of our App,

including the things that you’ve shared, your activity and things that we

collect. You will first need to choose the information that you want to

download and when the files are ready, you can download them to your

device. If you require your data logs, a request will need to be made to

the Chumba Support Request Form either here

or by email to

dataprivacy@vgw.co, and this request may take up to 30 days’ to

process. Data logs are additional details we collect and store that can be

associated with you. This data can be unique but it can also be additional

details about information provided in your account, such as the things

you’ve viewed or clicked on.

Delete your

information or

account

You can permanently delete your account in our App. If you delete your

account, we delete your information, including your activity, unless we

need to keep it as described in section 10, How Long Will We Retain

Your Information For. Once your account is permanently deleted, you

won’t be able to reactivate it, and you won’t be able to retrieve

information. If you request that we delete your account or information, it

may take up to 30 days to delete your information or account. We may

retain Personal Information that has been de-identified or aggregated.

We may retain information necessary for us or our service providers and

data processors to comply with certain legal and regulatory obligations.

Once we receive your request, we may verify it through your account or by requesting information

sufficient to confirm your identity. In some jurisdictions you are able to use an authorized agent to exercise

your rights; we may request evidence that you have provided such agent with a power of attorney or that

the agent has valid written authority to exercise your rights on your behalf.

9. HOW WE PROTECT YOUR INFORMATION

9.1. We use physical, electronic, and operational procedures to protect the information we gather. We follow

appropriate practices for collecting, storing and handling data, along with security measures to prevent

unauthorized access, changes, exposure or loss of your Personal Information. We regularly review and

update our security measures to stay current with technological advances.

9.2. If we believe that a notifiable data breach has occurred, we will comply with the legislative requirements to

notify you of the data breach and any steps taken by VGW to contain and investigate the data breach.

10. HOW LONG WILL WE RETAIN YOUR INFORMATION

10.1. We will retain the categories of Personal Information listed in section 3 above for various periods of time to

reasonably fulfil the purposes specified in this Privacy Policy which will be determined based on (1) the

length of time we need to retain the information to achieve the business or commercial purpose for which it

was obtained; (2) any legal, accounting, reporting or regulatory requirements applicable to such

information; (3) internal operational needs; and (4) any need for the information based on any actual or

anticipated investigation, dispute or litigation.

10.2. We will take reasonable steps to destroy or permanently de-identify any Personal Information where:

a) we no longer need the Personal Information for any purpose for which the Personal Information was

collected; and

b) we are not required by law, a regulator or a court/tribunal order, to retain the Personal Information.

11. SHARING YOUR INFORMATION

11.1. We share your Personal Information with the following categories of third parties:

a) Affiliates – other companies in the VGW Group;

b) Service providers and data processors – other companies who provide services to you on our behalf

or process your data on our behalf; and

c) Third parties that interact with us in connection with the services we perform.

11.2. If we share your Personal Information with a third party, we will take reasonable steps to ensure your

information is protected to the same standards as we protect our own and prohibit them from using your

Personal Information for purposes other than those requested by us or required by law.

11.3. WITH THIRD PARTIES

We only share information with third parties in limited circumstances including the following:

a) when you allow us to share your information with third parties;

b) when providing you with products and services and notifying you about important changes or

developments to the features and operation of those products and services;

c) with our service providers to enable us to offer our services, such as companies that help us with

things like technology, storing and combining data, processing payments, or providing relevant

marketing and advertising for our products and services. Where service providers use Personal

Information for their own purposes, where permitted by law, such service providers will act as the

data controller of that data;

d) in response to lawful requests by public authorities, including to meet national security or law

enforcement requirements, when ordered to do so by any regulatory body and/or under any legal

provision contained in the governing law of a particular jurisdiction;

e) to enforce our terms and conditions set out in our App, to protect our rights and property and the

rights and property of our customers and third parties, to detect fraud or other illegal activities and to

comply with law or legal processes; and

f) when performing web analytics to analyze traffic and player activity.

11.4. GOOGLE

We make available an API provided by Google to allow you to use your Google Account to sign into the

Website. You can manage this connection at any time via your Google Account. More information can be

found here

11.5. OTHER THIRD PARTIES

We may also share generic aggregated demographic information not linked to any personal identification

information regarding visitors and users of our App with our service providers, affiliates and advertisers for

the purposes outlined above.

11.6. TRANSFERS OF DATA

The VGW Group operates in several international jurisdictions and Personal Information we collect may be

transferred to, and stored and processed by, affiliates within the VGW Group or service providers in the

European Union, the United States, Canada, Australia, the Philippines or any other country in which we or

our service providers maintain facilities. We will ensure that transfers of Personal Information to any

country or organization are subject to appropriate safeguards. Additionally, without limitation and where

applicable, when transferring Personal Information from the European Union, we may use standard

contractual clauses approved by the European Commission or otherwise in accordance with European

protection laws for ensuring adequate safeguards.

12. MINORS

12.1. Protecting the privacy of children is especially important to VGW. For that reason, we never knowingly

collect or maintain information from individuals under the age of 18, and no part of the App is structured to

attract anyone under the age of 18. VGW does not offer or direct any of its services or products, including

the App, to individuals under the age of 18.

12.2. Do-Not-Track Signals and Similar Mechanisms

Some browsers may transmit “do-not-track” signals to the websites and/or apps with which the user

communicates. Due to the different ways that browsers incorporate and activate this feature, it is not

always clear whether users intend for these signals to be transmitted, or whether they are even aware of

them. As there is currently no industry standard concerning what, if anything, websites and/or apps should

do when they receive such signals, the Chumba Lite App currently does not take action in response to

these signals. If and when a final standard is established and accepted, we will reassess how to respond

to these signals.

13. CHANGES TO THIS PRIVACY POLICY

13.1. This Privacy Policy may be updated from time to time to reflect changes in the way we work or the way our

work is regulated. We will notify you of material changes and, where required by law, will obtain your

consent. Notice may consist of posting such changes on the App or by other means in accordance with

applicable laws.

13.2. Any changes to the Privacy Policy will become effective when the updated policy is posted on the App

and/or Website.

13.3. We encourage you to frequently check for any changes to stay informed about how we are helping to

protect the Personal Information we collect.

13.4. This Privacy Policy, in effect as of the last modified date stated at the top of the document, supersedes and

replaces any and all Privacy Policies previously in effect.

14. CONTACTING US

If you have specific questions regarding your Personal Information, how we process or use it, or to exercise

your rights, please contact our Privacy Team directly by email at dataprivacy@vgw.co

or alternatively please

complete the Privacy Request Form here.