Whenever we say “we”, “us”, or “our”, this should be read as BettyGaming CA Ltd, a company registered at 199 Bay Street, Suite 4000, Toronto, Ontario M5L 1A9. We respect your privacy and are committed to protecting it by complying with this policy. Betty’s platform (https://betty.ca) is offered as part of the open and regulated igaming market in Alberta conducted and managed by Alberta’s iGaming Corporation (“AiGC”) and we are collecting, using, and disclosing Personal Information on behalf of, and as agent to, AiGC. The Personal Information collected, used and disclosed by us on behalf of AiGC is collected, used and disclosed pursuant to sections 4(a) and 4(c) of Alberta’s Protection of Privacy Act (“POPA”), the Access to Information Act (“ATIA”), Personal Information Protection Act (PIPA) and any applicable regulations made under the Gaming, Liquor and Cannabis Act (Alberta) and our Operating Agreement with AiGC. Betty is committed to collecting, using, and disclosing your Personal Information responsibly and in compliance with applicable laws, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and An Act to promote the efficiency and adaptability of the Canadian economy by regulating certain activities that discourage reliance on electronic means of carrying out commercial activities, and to amend the Canadian Radio-television and Telecommunications Commission Act, the Competition Act, the Personal Information Protection and Electronic Documents Act and the Telecommunications Act (Canada) (“CASL”). This Privacy Policy is governed by the laws of Alberta, and the federal laws of Canada applicable therein. This policy describes: • How we collect, use, disclose, and protect the information of our customers (“Users”, “you”). • The types of information we may collect from you or that you may provide when you visit the website, when you send us SMS, email, or other ways that you interact with us. • Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy outlines our privacy statement and represents our commitment to you which describes how we deal with the information you provide to us. What is the purpose of this Privacy Policy? This Privacy Policy aims to inform you how we gather, process and protect your personal information when you use our services through our website or mobile application. What is personal information, non-personal information and data derived from personal information? Personal Information means recorded information about an identifiable individual. Non-personal data means data, including derived from personal information, that has been generated, modified or anonymized so that it does not identify any individual, and includes synthetic data and any other type of non-personal data identified in Privacy Laws. Data derived from personal information means data created by data matching and data that identified any individual whose personal information was used in the data matching. As an agent of the AiGC we will use your Personal Information in accordance with this policy and our operating agreement with the AiGC unless otherwise required by applicable laws. We take steps to ensure that the Personal Information we collect about you is adequate, relevant, not excessive, and used for limited purposes. We may also receive information from our providers while protecting you from harm such as anti-money laundering, fraud, and through our Know Your Customer (“KYC”) processes. Any such information will be treated as Personal Information and used and processed in the same way. Any Personal Information that we store, collect, and use is to help us manage your relationship with us. Sometimes, with your consent, we may use this information to send you marketing offers, or other information that you may find useful. Please read this policy carefully to understand our policies and practices for collecting, using, processing, disclosing, and storing your information on behalf of AiGC. If you do not agree with our policies and practices, your choice is not to use Betty. To register for an account on Betty, you will be required to indicate that you understand, accept, and consent to the practices described in this policy. Betty is not intended for individuals under 18 years of age (“Minors”) and the company does not knowingly collect information relating to Minors. If you are the parent or guardian of a Minor who has provided us with their Personal Information, please contact Betty via the contact information below and we will delete such Personal Information.

We welcome your questions, comments, and requests regarding this Privacy Policy and our privacy practices. Please contact us at: Betty Gaming Privacy Officer 199 Bay Street, Suite 4000, Toronto, Ontario M5L 1A9 email: compliance@betty.ca phone: 1 (437) 837-1061 Working Hours: Monday to Friday, from 7:00 am to 3:00 pm. Betty has procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. If your complaint about the collection, use or disclosure of personal information has not been resolved through normal Customer Service channels, you may ask the Privacy Officer to resolve questions or concerns. To do so, you may contact the Privacy Officer using the contact information provided above. If you are not satisfied with our response to your complaint, you can request a copy of your case file to raise your complaint or concerns with the AiGC. You also have a right to file a formal complaint with the Alberta Information and Privacy Commissioner if you suspect your personal information has been collected, used or disclosed in contravention of POPA.

We will collect the following types of Personal Information: 1. Information that you input directly into forms on Betty, at the time of registration, or any other communication such as email or SMS, including but not limited to your name, address, contact details, age, date of birth, verification data/documents, payment methods details used to make deposits on our platform, financial and employment position, etc. 2. Information that you give us over the phone inputted on your behalf by one of our agents. 3. A record of all chat, SMS, email, and phone correspondence that you take part in. 4. Contacts made via any of our social media channels. 5. Transactional information that you carry out by any means. 6. Games you play, bets you place, and any financial outcome related to those. 7. Surveys, customer research, or any other type of data you give voluntarily. 8. Betty visits, including location and technical information such as IP address and any other technical data related to your visit, which may include pages visited, click data, and other analytical information. 9. Verification details and documents through a third-party identity verification provider. 10. Publicly available Personal Information from sources such as internet searches and media to assist us in fulfilling our obligations relating to fraud prevention and anti-money laundering only where it is legal to do so and will not infringe your rights and legal protections. 11. Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. This type of information will not be re-identified. Aggregate personal information may also be shared with Alberta’s iGaming Corporation.

We collect, use or disclose personal information on behalf of, and as an agent to, AiGC, for appropriate or reasonable purposes, the collection is limited to what is necessary or reasonable to meet those purposes. We use information that we collect about you or that you provide to us, including any Personal Information: 1. To present Betty’s services and contents to you. 2. To provide you with information, products, or services that you request from us. 3. To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it. 4. To provide you with notices about your account. 5. To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements. 6. To input it into an automated system to generate content or make decisions, recommendations or predictions. 7. To notify you about changes to Betty or any products or services we offer or provide through it. 8. To improve Betty, our products or services, marketing, or customer relationships and experiences. 9. To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you. 10. In any other way we may describe when you provide the information. 11. Any telephone calls, emails, and chats that you take part in our Customer Support, payments, and other customer-facing teams will be recorded for training purposes, and where a legal contract is made via telephone, to verify this contract and ensure that the level of service you received was to the correct standard. 12. For any other purpose with your explicit consent. We may also use your information to contact you about our own and third parties' goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please check the relevant box at the time of registration, adjust your user preferences in your account profile, use the unsubscribe mechanism at the bottom of our e-mails, or e-mail us at unsubscribe@betty.ca.

Your Personal Information is always protected in a safe, secure way according to our obligations as an agent of AiGC and our operating agreement, the applicable law and our own high standards. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of Betty’s system, you are responsible for keeping this password confidential. We ask you not to share your password with anyone to assist us in preventing account or identity theft. Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to Betty. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on Betty. We will retain your Personal Information for only as long as necessary to fulfill the purposes outlined in this Privacy Policy. In addition, we will retain your Personal Information as required to enable us to meet our legal obligations under applicable laws or regulations, such as the applicable privacy laws, gambling regulations, Know-Your-Customer, Responsible Gaming and Anti-Money Laundering regulations, and our obligations to AiGC. Details of retention periods for different aspects of your Personal Information can be requested by us through contacting our Support team. We have procedures to deal with any suspected or actual Personal Information breaches. Betty strives to mitigate any possible privacy risks. However, in case of such situation, we will immediately notify AiGC and any other relevant authorities, where applicable, for the incident and cooperate with any investigation, as well as with mitigating the incident and any negative consequences.

As well as being subject to privacy laws, we have operating and legal obligations to uphold, which means that we must do checks on identification, address, and age to prevent things such as fraud and to comply with anti-money laundering regulations. It would be impossible for us to do this without processing your Personal Information. If you choose not to provide us with Personal Information, we will be unable to open an account for you and provide you with our services, as it would mean we are unable to fulfill our registration conditions, contractual obligations to AiGC, and other legal obligations required to operate your account.

We will only share your information when it is necessary to fulfill our obligations to you, to AiGC or where there is a legal obligation. Below are some examples: 1. To carry out fraud checks. 2. To verify your identity. 3. To confirm deposit or withdrawal details. 4. Where we are compelled to do so by a law enforcement agency, regulator, or other government body. 5. To return Personal Information to an organization that introduced you to us. 6. To third parties whenever it is necessary to be able to deliver the service you requested. 7. Limited gaming data may be shared with another provincial operator to the extent strictly necessary to identify and link or match other provincial igaming account. 8. Other third parties where you permit us to do so. We may also disclose your personal information: 1. To comply with any court order, law, or legal process, including responding to any government or regulatory request, in accordance with applicable law and our operating agreement. 2. To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes. 3. If we believe disclosure is necessary or appropriate to protect our rights, property, or safety, our customers, or others. This includes exchanging information with the AiGC, other companies and organizations for the purposes of fraud protection and credit risk reduction. 4. To another organization involved in a potential or completed business transaction to the extent such disclosure may be permitted by AiGC (such as a merger, sale, or financing), provided that the parties have entered into an agreement to use the information solely for purposes related to the transaction, to protect the information with appropriate safeguards, and to return or destroy the information if the transaction does not proceed. If a business transaction is completed, we will notify you that the transaction has occurred and that your personal information has been transferred. We may transfer Personal Information that we collect or that you provide as described in this policy to contractors, service providers (which may include information from your telecommunications provider) and other third parties, we use to support our business and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy and our operating agreement with the AiGC. We may process, store, and transfer your personal information outside Alberta, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. We are committed to protecting your Personal Information and we oblige our service providers to handle your Personal Information in accordance with PIPEDA, POPA, ATIA, PIPA, the rules set out by the applicable Gambling and Gaming Commissions to which we are subject as a gambling operator, our operating agreement and the terms of this Privacy Policy. More specifically, your personal information will be shared with our third-party providers and will be collected, stored, used and retained in the following countries: Bulgaria, Ireland, Germany, the United Kingdom, Belgium, Netherlands, United States, United Arab Emirates, Poland. The purpose for which our service providers use, collect, store and retain your personal information outside Canada is (i) to provide you with access to our services, (ii) verify your identity, (iii) process your transactions, (iv) provide you with marketing communications when you previously opted in. Your personal data may be combined with Non-Alberta Personal Data held by us in order to provide you with the Services. In such cases, we maintain safeguards to ensure that the level of protection remains consistent with Alberta’s privacy standards and all other applicable laws. For the operation of our business, your Personal Information may be shared with group companies that are either parent, associate, or subsidiary. In the event of a succession of ownership of our business, your Personal Information may also be transferred as part of that process to the extent this transfer may be permitted and approved by the AiGC. We may share aggregated information about our users, and information that does not identify any individual, without restriction, including with the AiGC.

We are required to keep the Personal Information we hold about you accurate and up to date. Please keep your Personal Information up to date in your account and inform us if your Personal Information changes. By law you have the right to request access to and to correct the personal information that we hold about you. If you want to review, verify, correct, or withdraw consent to the collection, use, or disclosure of your personal information you may contact our Privacy Officer in writing and make such a request. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may request specific information from you to help us confirm your identity and your right to access. Once we receive your written request for access, we will provide a response outlining the follow-up actions required in line with POPA, ATIA and our operating agreement. Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact our Privacy Officer. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service and we may need to terminate our business relationship and remove your user account. We will explain the impact to you at the time to help you with your decision.

We may, from time to time, change or update this Privacy Policy. It is our policy to post any changes we make to our Privacy Policy on this page. If we make material amendments to how we treat, collect, use, or disclose your personal information, we will require you to accept and consent to the amended Privacy Policy prior to accessing Betty.