PRIVACY POLICY

Last update: December 15, 2025

Introduction

This Privacy Policy explains how UP-X (hereinafter “the Company”, “We”, “Us”, or “Our”) collect, use, store, disclose, and safeguard personal data when you ("User", "You", or "Your") access or use our platform and associated services (collectively, the “Platform”).

By registering an account, accessing any part of the Platform, or voluntarily providing personal information, you acknowledge that you have read, understood, and accepted the terms of this Privacy Policy. If you do not agree with this Policy or any part of it, you must refrain from using the Platform or submitting personal data.

We are committed to processing personal data lawfully, fairly, and transparently, in accordance with the applicable law and other regulations. This Policy provides clear information about:

The types of personal data we collect;

The purposes and legal grounds for processing your data;

How and with whom your data may be shared;

Your rights regarding personal data and how to exercise them;

The safeguards in place to protect your privacy.

The Platform is intended only for users who have reached the age of majority in their jurisdiction (or at least 18 years old). We do not knowingly collect personal data from minors. If we become aware that such data has been collected, we will promptly delete it and, where applicable, deactivate the associated account.

1. Who we are

We act as the Data Controller, which means we determine the purposes and legal basis for processing your personal data.

Data Controller Information:

Contact Email: support@xp5byq04u.life

2. Categories of Personal Data Collected

2.1. We collect personal data from various sources, which are detailed in section 3 of this Policy. The categories of data collected include:

A. Data Provided Directly by You

This includes personal information you voluntarily provide when interacting with our Services, such as:

Full name, date of birth, and contact details (email, phone number, residential address);

Payment information necessary for processing transactions;

Documents submitted for verification or compliance purposes;

Communications with customer support, including inquiries and feedback.

B. Data Generated Through Use of Our Services

During your use of the platform, we may collect data related to your activities, including:

Content you create or submit within the platform;

Records of your transactions and betting history;

Technical details about the device and browser used to access the Services;

Log data including IP address, access timestamps, and navigation patterns.

C. Automatically Collected Technical Data

Certain information is gathered automatically as you access and use the Services, such as:

IP address and approximate geographic location;

Browser type, operating system, and device identifiers;

Language preferences and user settings;

Diagnostic information, including error and crash reports.

2.2. This data is utilized to provide, maintain, enhance, and secure our Services, as well as to ensure compliance with legal and regulatory obligations.

3. Sources of Personal Data

3.1. We collect personal data directly from you when you interact with our Platform, including during registration, account management, deposits, withdrawals, and customer support communications.

Additionally, we may obtain personal data from the following sources:

A) Third-party service providers, such as payment processors, identity verification services, and marketing partners;

B) Publicly available sources, including social media or publicly accessible databases;

C) Automated technologies, including cookies, web beacons, and other tracking tools that collect information about your usage of our Platform.

3.2. We ensure that any personal data obtained from third parties is handled in accordance with applicable data protection laws and with respect to your privacy rights.

4. Purpose and Legal Basis for Processing

4.1. We collect and process your personal data strictly for defined and lawful purposes, each supported by one or more legal bases under applicable data protection laws.

A. Provision of Services. We process your data to create and maintain your Account, provide access to our gaming platform, deliver bonuses and promotional offers, and ensure the proper technical operation of our Services.

Legal basis: Contractual necessity: to fulfil the agreement between you and the Operator.

B. Identity Verification and Compliance. Your information is used to verify your identity, conduct Know Your Customer (KYC) procedures, and comply with Anti-Money Laundering (AML) and counter-terrorism financing requirements, as mandated by law.

Legal basis: Legal obligation: to meet applicable regulatory standards.

C. Financial Transactions. We process personal and financial data to accept deposits, execute withdrawals, manage account balances, and investigate or resolve payment-related disputes.

Legal basis: Contractual necessity; Legal obligation for financial record-keeping.

D. Personalization and Service Improvement. We analyse usage patterns and preferences to tailor offers, promotions, and recommendations to your interests, and to improve the functionality, security, and performance of our platform.

Legal basis: Legitimate interests: to enhance user experience; Consent, where required for marketing or profiling.

E. Customer Support and Communication. We use your contact details and account information to respond to your requests, provide assistance, and send important service-related updates.

Legal basis: Contractual necessity; Legitimate interests in ensuring efficient communication.

F. Fraud Prevention and Security. Data is processed to detect, investigate, and prevent fraudulent transactions, abuse of services, or other illegal or harmful activities, and to safeguard the integrity of our systems.

Legal basis: Legitimate interests in protecting the platform; Legal obligation where reporting is required.

G. Legal and Regulatory Compliance. We retain and disclose certain data to meet tax, anti-fraud, licensing, and other statutory requirements applicable in our jurisdiction.

Legal basis: Legal obligation.

H. Protection of Vital Interests. In rare circumstances, we may process data to protect your safety or that of another individual.

Legal basis: Vital interests.

5. How We Use Your Data

5.1. We process personal data only for purposes that are consistent with our obligations, the nature of our Services, and applicable law. Specifically, your data may be used to:

A. Provide and maintain our Services. Operate the gaming platform, register and manage Accounts, enable participation in games, process transactions, and ensure technical functionality.

B. Optimize and enhance user experience. Analyse platform usage, develop new features, and deliver content, offers, and recommendations tailored to your interests.

C. Ensure legal and regulatory compliance. Fulfill obligations related to licensing, responsible gaming, Anti-Money Laundering (AML), Know Your Customer (KYC), taxation, and record retention.

D. Safeguard platform integrity. Detect, investigate, and prevent fraud, security breaches, misuse of services, or violations of our Terms and Conditions.

E. Provide support and resolve disputes. Respond to your inquiries, handle complaints, and mediate any account- or transaction-related issues.

F. Communicate important updates. Notify you about changes to our services, terms, or policies, and send legally required notices.

6. Data Sharing and Disclosure

6.1. We do not sell or rent your personal data. However, we may share it with carefully selected third parties where such disclosure is lawful, necessary for the provision of our Services, or required by applicable regulations. Specifically, your data may be disclosed to:

A. Affiliated entities. Companies within our corporate group that support the operation, development, and maintenance of the Platform.

B. Authorized service providers. Trusted partners engaged to perform services on our behalf, including payment processing, identity verification, AML/KYC compliance, fraud prevention, analytics, hosting, and customer support.

C. Regulatory bodies and law enforcement. Government agencies, supervisory authorities, or courts, where disclosure is required by law, regulation, or court order.

D. Professional advisers. Legal, tax, audit, and other consultants bound by professional confidentiality obligations.

E. Corporate transactions. Potential or actual buyers, investors, or partners in the event of a merger, acquisition, restructuring, or sale of assets, provided they commit to handling your data in accordance with this Privacy Policy.

F. With your explicit consent. Any other sharing will occur only where you have given clear and informed consent.

6.2. All third parties with whom we share your data are contractually required to maintain strict confidentiality, implement appropriate security measures, and use your personal data solely for the purposes for which it was provided.

7. International Data Transfers

7.1. Your personal data may be processed or stored in countries outside your country of residence, including jurisdictions that may not offer the same level of data protection as your home jurisdiction. Such transfers are sometimes necessary for us to operate the Platform, deliver our Services, and meet legal or contractual obligations.

7.2. When transferring data internationally, we implement appropriate safeguards to ensure that your personal data remains protected, including:

A. For Users located in the European Economic Area (EEA) or other jurisdictions with equivalent data protection frameworks – applying Standard Contractual Clauses (SCCs) or other transfer mechanisms approved by the European Commission or relevant authorities under applicable law.

B. Transferring data only to countries officially recognized as providing an adequate level of protection for personal data.

C. Where applicable, ensuring that third-party recipients are contractually bound to comply with strict confidentiality, security, and data protection requirements.

These measures are designed to protect your information regardless of where it is processed.

8. Data Retention

8.1. We retain your personal data only for as long as it is necessary to achieve the purposes for which it was originally collected, including to comply with legal, regulatory, tax, accounting, or reporting requirements, as well as to protect our legitimate business interests. Once the relevant purposes no longer apply, and provided no legal, contractual, or regulatory obligations require continued retention, your data will be securely deleted, erased or irreversibly anonymized.

8.2. Please note that certain categories of personal data may be retained beyond the closure of your Account or a deletion request in the following cases:

A. Where retention is necessary to safeguard our legitimate interests or those of a third party, comply with official requests from governmental or regulatory bodies, resolve disputes, investigate issues, or enforce agreements you have entered into with us.

B. Where the data has been irreversibly anonymized so that it can no longer be linked to you and therefore ceases to constitute personal data under applicable laws.

C. Where continued retention is required to comply with Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and other statutory or regulatory obligations, regardless of whether you have requested deletion.

We regularly review the data we hold to ensure it is kept only for as long as strictly necessary.

9. Data Subject Rights

9.1. You possess the following rights with respect to your personal data, subject to applicable legal limitations:

A. Right to Access. You may request confirmation whether we process your personal data and receive a copy, along with information on the purposes of processing, categories of data, and recipients.

B. Right to Rectification. You may request correction or updating of any inaccurate, incomplete, or outdated personal data we hold about you.

C. Right to Erasure. You may request deletion of your personal data when it is no longer needed, when consent is withdrawn, when processing is unlawful, or when deletion is required by law.

D. Right to Restrict Processing. You may request limitation of processing in certain situations, such as when disputing accuracy or objecting to processing.

E. Right to Object. You may object to processing based on our legitimate interests or for direct marketing purposes. We will stop processing unless there are compelling legal grounds to continue.

F. Right to Data Portability. You may request to receive your personal data in a structured, commonly used, machine-readable format or have it transferred directly to another controller, where technically feasible.

G. Right to Lodge a Complaint. You have the right to lodge a complaint with the competent supervisory authority if you believe that your personal data has been processed in violation of applicable data protection laws.

We will handle all requests in accordance with applicable laws and within statutory deadlines.

10. Security Measures

10.1. We apply appropriate technical and organizational measures to safeguard the confidentiality, integrity, and availability of your personal data, including:

A. Encryption technologies and secure communication protocols;

B. Access controls, authentication mechanisms, and role-based permissions;

C. Regular system monitoring, vulnerability assessments, and security audits;

D. Employee training on data protection and binding confidentiality obligations.

10.2. Although we take all reasonable steps to protect your information, no method of transmission or storage is entirely secure. You are responsible for keeping your Account credentials confidential and for all activities carried out under your Account.

11. Cookies and Tracking Technologies

11.1. We use cookies and similar tracking technologies to enhance your experience, analyze site usage, and provide personalized content and offers. These technologies may include:

A. Session and persistent cookies for website functionality and user authentication;

B. Analytical cookies to monitor performance, traffic, and usage patterns;

C. Targeting or advertising cookies to deliver relevant promotions or third-party content.

11.2. You can manage or disable cookies through your browser settings. However, some features of the Services may not function properly if cookies are blocked or removed.

11.3. By using our Services, you consent to the placement and use of cookies and similar tracking technologies as described in this Policy.

12. Changes to This Privacy Policy

12.2. We are not required to notify Users individually about any updates or modifications. Users are responsible for reviewing the Policy periodically to stay informed of changes.

12.3. Continued use of the Platform or Services after the publication of a revised Privacy Policy constitutes acceptance of the new terms. If you do not agree with the updated Policy, you must discontinue using the Platform.

12.4. The Platform reserves the right, at its sole discretion, to modify, update, or replace this Privacy Policy as necessary to comply with applicable laws, regulatory requirements, or operational needs.

13. Dispute Resolution and Governing Law

13.1. Any dispute, controversy, or claim arising out of or in connection with this Privacy Policy, including its existence, validity, interpretation, performance, breach, or termination, shall be governed by and construed in accordance with the laws of the jurisdiction where the Company has incorporated and operates.

13.2. By using the Platform, you irrevocably agree that:

A. All disputes shall be subject to the exclusive jurisdiction of the competent courts of the jurisdiction where the Company has incorporated and operates;

B. You waive any right to challenge the venue or jurisdiction based on inconvenient forum or lack of personal jurisdiction;

C. Prior to initiating legal proceedings, both parties shall make reasonable efforts to resolve the matter amicably through written notice and direct negotiation;

D. This clause applies to all disputes related to the collection, processing, and protection of personal data under this Privacy Policy.

14. Contact Information

14.1. For any questions, requests, or concerns regarding your personal data or this Privacy Policy, you may contact us at:

Email: support@xp5byq04u.life

14.2. We will respond to inquiries in accordance with applicable laws and strive to resolve any issues promptly.