BLUEBET COLORADO PRIVACY POLICY

Last modified: 20 March 2023

Introduction

ClutchBet ("Company" or "We"), respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes: (a) the types of information we may collect or that you may provide when you use www.clutchbet.com (the “website”) or purchase, download, install, register with, access, or use the BlueBet™ Colorado mobile website or website or Application (the "website or App"); and (b) our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy website or website or Applies only to information we (or our authorized representatives and contractors) collect in the website or the website or App and in email, text, and other electronic communications sent through or in connection with the website or the website or App. This policy DOES NOT website or website or Apply to information that: (a) we (or our authorized representatives) collect offline or on any other Company website or website or Apps or websites, including websites you may access through this website or website or App; or (b) you provide to or is collected by any third party. Our website and website or website or Apps, and these third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this website or website or App. By downloading, registering with, or using this website or website or App, you agree to this privacy policy. This policy may change from time to time. Your continued use of this website or App after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Persons Under the Age of 21

YOU MUST BE 21 YEARS OF AGE OR OLDER TO DOWNLOAD, REGISTER
WITH OR USE THE WEBSITE OR APP. We do not knowingly collect personal information from persons under 21. If we learn we have collected or received personal information from a person under 21,,we will delete that information.

Information We Collect and How We Collect It

We collect information from and about users of our website or App directly from you when youprovide it to us (or our authorized representatives) and automatically when you use the
website or App.

Information You Provide to Us (or our Authorized Representatives)

When you download, register with, or use this website or App, we (or our authorized representatives) may ask you to provide information: (a) by which you may be personally
identified, such as name, postal address, email address, social security number (or a portion thereof), date of birth, telephone number, or any other information the website or App collects that is defined as personal or personally identifiable information under a website or Applicable law ("personal information"); and (b) that is about you but individually does not identify you.

This information includes:

• Information that you provide by filling in forms in the website or App. This includes information provided at the time of registering to use the website or App and posting material. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the website or App.
• Records and copies of your correspondence (including email addresses andphone numbers), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Financial information and details of transactions you carry out through the website or App and of the fulfillment of same. You may be required to provide financial information before using some or all of the website or App.
• Your search queries on the website or App.

You may provide information to be published or displayed ("Posted") on public areas of thew website or App and/or websites you access through the website or App (collectively, "User Contributions"). Your User Contributions are Posted and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Automatic Information Collection and Tracking

When you download, access, and use the website or App, it may use technology to collect:

• Usage Details. When you access and use the website or App, we may collect
  certain details ofyour access to and use of the website or App, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the website or App.
• Device Information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number.
• Stored Information and Files. The website or App also may access metadata and other information associated with other files stored on your device. This may include,for example, photographs, audio and video clips, personal contacts, and addressbook information.
• Location Information. This website or App may collect real-time information about thelocation of your device and other location and access characteristics.

If you do not want us to collect this information, do not download the website or App or delete it from your device. We also may use these technologies to collect information about your activitiesover time and across third-party websites, website or website or Apps, or other online services (behavioral tracking).

Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include, without limitation:

• Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activatingthe website or website or appropriate setting on your smartphone. However, if you select this setting, you may be unable to access certain parts of our website or App.
• Web Beacons. Pages of the website or App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single- pixel gifs) that permit the Company, for example, to count users who have visitedthose pages or opened an email and for other related website or website or App statistics (for example, recording the popularity of certain website or website or App content and verifying system and server integrity).

Third-Party Information Collection

When you use the website or App or its content, certain third parties may use information collection technologies to collect information about you or your device. These third parties may include advertisers, payment processers or conduits, payment gateways, central account management systems, third-party verification service provider systems, geolocation and geofencing service providers, ad networks, ad servers, analytics companies, your mobile device manufacturer, your mobile service provider, our affiliates and others. These third parties may use tracking technologies to collect information about you when you use this website or App. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, website or website or Apps, and other online services websites. They may use this information to provide youwith interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. Ifyou have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we (or our authorized representatives) collect about you or thatyou provide to us (or our authorized representatives), including any personal information, to:

• Provide you with the website or App and its contents, and any other information, products orservices that you request from us.
• Fulfill any other purpose for which you provide it.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection, if website or website or Applicable.
• Notify you when website or App updates are available, and of changes to any products orservices we offer or provide though it.
• Confirm that you are accessing the website or App from an website or website or Approved location.
• Comply with any court order, law, or legal process, including to respond to anygovernment or regulatory request.

The usage information we collect helps us to improve our website or App and to deliver a better andmore personalized experience by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our website or Appaccording to your individual interests.
• Speed up your searches.
• Recognize you when you use the website or App.

We may also use your information to contact you about our own, our affiliates’ and thirdparties' goods and services that may be of interest to you. We may use the information we collectto display advertisements to our advertisers' target audiences.

In addition to the above, you hereby understand, agree and consent to the collection of any and all information required to be collected, or that may be collected, by us (or our authorized representatives) in accordance with the Colorado Gaming Laws (as defined below), our house rules, our terms and conditions, our procedures, the Bank Secrecy Act, FinCEN requirements, and/or other website or Applicable laws, whichinformation may include, without limitation, your identity, personal information, geographic location, wagers, wagering history, tax identification number(s), financial information, wagering patterns and/or website or App access (regardless of whether any wager is actually placed) (collectively, "Patron Data"). You hereby consent to, and release Company and its related persons and entities from all claims, liabilities and damages relating to (and covenant not to sue Company or its related persons or entities in relation to), the disclosure at any time, and from time to time, of Patron Data without notice to you to the Regulatory Authorities (as defined below), financial institutions, state and federal law enforcement agencies (including, without limitation, FinCEN), the Internal Revenue Service, wagering service providers, wagering integrity service providers, and/or other third parties as may be necessary or website or website or Appropriate, as determined in Company's sole discretion, for Company to perform its compliance functions. For purposes of these Terms, "Colorado Gaming Laws" means all laws pursuant to which any Regulatory Authority possesses regulatory, licensing or permit authority over gaming within the State of Colorado, as amended from time to time,and the regulations promulgated thereunder, as amended from time to time; and "Regulatory Authorities" means the Colorado Division of Gaming and all other state and local regulatory and licensing bodies with authority over gaming in the State of Colorado and its political subdivisions.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

In addition, we may disclose personal information that we (or our authorized representatives) collect or you provide:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business.
• To a buyer or other successor in the event of a merger, divestiture, restructuring,reorganization, dissolution, or other sale or transfer of some or
  all of Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our website or App users is among the assets transferred.
• To third parties to market their products or services to you.
• To fulfill the purpose for which you provide it.
  For any other purpose disclosed by us when you provide the information.
• With your consent or otherwise consistent with this policy.
• To comply with any court order, law, or legal process, including to respond toany government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us,including the website or App Terms of Service, and for billing and collection.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Except as contemplated in this privacy policy, we will keep player account information confidential unless otherwise required by law.

Your Choices About Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us and our authorized representatives. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the website or App may then be inaccessible or not function properly.
• Location Information. You can choose whether or not to allow the website or App to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some partsof the website or App may then be inaccessible or not function properly.

We do not control third parties' collection or use of your information to serve interest- based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the website or App and visiting your account profile page. You may also send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. 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.

If you delete your User Contributions from the website or App, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by otherwebsite or App users.

Data Security

We have implemented 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 depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website or App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the website or App like message boards. The information you share in public areas may be viewed by any user of the website or App.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we strive to protect your personal information, we cannot guarantee the security of your personal information transmitted through our website or App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Without limiting the foregoing, we will securely erase from hard disks, magnetic tapes, solid state memory, and other devices all player information before we dispose of same.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users' personal information, we will post the new privacy policy on this page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contactus at [email protected].
In addition, to exercise any opt-out, access, data portability or deletion rights under website or website or Applicable law, please submit a verifiable consumer request in writing to us at [email protected].