PRIME WIN PRIVACY POLICY

Updated: August 15, 2026 Effective Date: August 15, 2026

Preamble and Authorization Rules

This Privacy Policy explains how Nova Trend Inc. (“Nova Trend,” “we,” “us,” or “our”) collects, stores, uses, shares, transfers, deletes, and protects personal information in connection with your use of PRIME WIN and its related services, including the game, online tournaments, official websites, in-app purchases, customer support (collectively, the “Services”).

This Privacy Policy should be read together with the User Service Agreement and any additional or just-in-time privacy notices provided in connection with specific features or processing activities. To the extent this Privacy Policy is incorporated by reference into the User Service Agreement, it forms part of the terms governing your use of the Services. If an additional or just-in-time privacy notice conflicts with this Privacy Policy regarding a specific processing activity, the more specific notice will control with respect to that activity.

Tiered Authorization Rules

(1) Necessary Data Processing: Account registration, basic device logs, anti-cheat risk control, and transaction records constitute essential data for normal gameplay and tournament participation. We determine the lawful basis for processing personal information based on specific processing purposes and applicable laws, including performance of a contract, compliance with legal obligations, legitimate interests, and, where applicable, obtaining your consent. For processing activities that require consent under applicable law, we will obtain your consent separately through appropriate means.

(2) Optional Authorizations and Feature-Specific Permissions: Marketing push notifications, photo album access, advertising identifiers, and precise geolocation may be requested through separate notices or permission prompts. You may decline or withdraw optional permissions at any time. Disabling an optional permission will not affect unrelated core functions. However, where precise geolocation is necessary to verify eligibility for a cash tournament or comply with geographic restrictions, declining or disabling location permission may prevent you from participating in the relevant tournament or feature.

Age Restrictions

Age eligibility requirements applicable to the Services are described in Section 6 of this Privacy Policy.

1. Personal Information We Collect, Purposes, and GDPR Lawful Basis

We strictly adhere to the principles of data minimization, lawfulness and fairness, and transparency. We collect only data necessary for the operation of the game and tournaments, and do not collect unrelated information beyond what is required. Each category of information is annotated with its GDPR lawful basis for processing.

1.1 Account and Profile Information

Collected Data: Username, account ID, authentication credentials, avatar, age or date of birth, email address, phone number, residential address, communication preferences, and other profile information you choose to provide.

Purpose: Account registration, authentication, account management, age and eligibility verification, customer communications, account recovery, and personalization of the Services.

Lawful Basis: Performance of our contract with you; compliance with applicable legal obligations; our legitimate interests in operating and securing the Services; and your consent where required by applicable law.

1.2 KYC and Withdrawal Rules

  1. When participating in cash tournaments, claiming cash rewards, or requesting withdrawals, we may require users to complete identity verification in accordance with applicable law, payment provider requirements, and risk control policies.
  2. Users must ensure that the identity, residential, and payment account information submitted is authentic, accurate, and belongs to the user personally.
  3. If a user has not completed the necessary identity verification, if identity information is inconsistent, if the account presents abnormal risk, or if further review is required by law, we may withhold tournament prize disbursements or withdrawal processing until the relevant review is completed.
  4. Specific withdrawal amount limits, processing times, fees, payment methods, and applicable taxes are governed by the officially published "Cash Tournament and Withdrawal Rules" on the game platform.

1.3 Device, Location, and Operational Log Information

Collected Data: Device model and type, operating system and browser version, device language, network type, mobile carrier, login IP address, unique device identifiers, application identifiers, advertising identifiers where authorized, login times, pages or features viewed, clicks and interactions, game match logs, tournament records, matchmaking and score data, application crash reports, performance and diagnostic logs, referral URLs, anti-cheat risk signals, and approximate location derived from your IP address. With your device permission, we may collect precise geolocation or GPS signals where necessary to verify eligibility for cash tournaments or comply with geographic restrictions.

Purpose: Server operations and maintenance, bug fixes, tournament fairness and anti-cheat enforcement, identification of multi-accounting, third-party tools, and collusion-based score manipulation, blocking users in restricted jurisdictions from participating in cash tournaments, and defense against cyber attacks.

Lawful Basis: Our legitimate business interests (ensuring fair competition for all players and account and fund security). You may exercise your right to object to data processing at any time and request restriction of processing based on risk-control profiling.

1.4 Recharge, Transaction, and Tournament Prize Information

Collected Data: Recharge order numbers, consumption details, payment channel receipts, registration fee records, tournament prize disbursement records, refund transaction records, and bank/payment account information.

Purpose: Order verification, virtual asset and tournament reward distribution, refund reconciliation, payment fraud prevention, prize settlement, and tax record retention and filing.

Lawful Basis: Performance of paid service contracts and statutory tax record retention obligations under applicable national laws.

1.5 User-Submitted Information

Collected Data: Customer-support requests, feedback, screenshots, cheat reports, tournament appeals, identity-verification materials, and any contact information, documents, or other evidence you choose to provide when communicating with us.

Purpose: Processing inquiries, account appeals, cheat reporting, tournament result reviews, and dispute mediation.

Lawful Basis: Performance of our contract with you; our legitimate interests in providing customer support, investigating misconduct, resolving disputes, and enforcing our rules; compliance with applicable legal obligations; and your consent where required by applicable law.

1.6 Information We Receive from Third Parties

Collected Data: We may receive personal information from third-party platforms and service providers, including third-party login providers, app stores, payment processors, identity- and age-verification providers, geolocation providers, fraud-prevention providers, and advertising or analytics partners. The information we receive may include account identifiers, profile information authorized by you, transaction status, payment confirmation, identity-verification results, age or residency verification results, location-verification results, fraud or security risk signals, and advertising or analytics information. The specific information we receive depends on the Services you use, your settings and authorizations, and the relevant third party’s privacy practices. We do not receive or store your password for a third-party login platform.

Purpose: Account authentication and linking; processing purchases, refunds, tournament prizes, and withdrawals; verifying identity, age, residence, location, and tournament eligibility; detecting and preventing fraud, cheating, abuse, and other prohibited conduct; measuring Service and advertising performance; and operating, securing, analyzing, and improving the Services.

Lawful Basis: Performance of our contract with you; compliance with applicable legal obligations; our legitimate interests in operating, securing, analyzing, and improving the Services; and your consent where required by applicable law.

1.7 Cookies and Similar Technologies

When you visit or access our Services, we and our authorized service providers may use cookies, local storage, software development kits (“SDKs”), and similar technologies to collect device, usage, gameplay, performance, and diagnostic information. We use these technologies to operate and secure the Services, remember your preferences, analyze Service performance, diagnose technical issues, prevent fraud and cheating, and improve the Services.

Where required by applicable law, we will obtain your consent before using non-essential analytics or advertising technologies. You may manage available choices through your browser or device settings and any privacy controls made available in the Services. Disabling certain technologies may affect the operation of some Service features.

1.8 Optional Non-Essential Information Subject to Authorization

  • Push Notifications: With your consent where required by applicable law, we may send marketing, promotional, event, and tournament-related push notifications. You may withdraw your consent or disable these notifications at any time through the notification settings made available in the Services or through your device settings. Disabling marketing or promotional notifications will not affect core functions such as account access, payments, withdrawals, or tournament participation.
  • Photo Album Access: Used solely for uploading avatars, appeal screenshots, and tournament materials; we do not silently access the photo album without user action.
  • Advertising Identifiers (IDFA/GAID/OAID): Where permitted by applicable law and subject to your device settings, consent, or other applicable privacy choices, we and our authorized advertising or analytics partners may use advertising identifiers to measure advertising performance, perform attribution, limit repeated advertisements, analyze the effectiveness of marketing campaigns, and provide personalized content or advertising. You may manage or reset advertising identifiers and limit personalized advertising through your device settings or any privacy-preference tool made available in the Services.

Where required by applicable law and tournament eligibility rules, we may obtain or verify region-related information when you enter, participate in, or withdraw from cash tournaments to confirm whether you are located in a permitted region. Unless otherwise stated, we do not continuously collect precise geolocation for general game functions.

2. Boundaries of Personal Information Use

We may only use collected personal information for the following compliant purposes and shall never process data beyond the specified scope or purpose:

  • Providing, maintaining, and optimizing the game and all types of tournament services;
  • Account security protection, anti-cheat risk control, and combating tournament violations such as multi-account score manipulation and match collusion;
  • Recharge billing, prize disbursement, refund processing, customer service appeals, and tournament result reviews;
  • Fixing program defects, iterating game features, and optimizing tournament matchmaking mechanisms;
  • Complying with national regulatory laws, app store policies, and tax filing requirements;
  • Sending marketing, promotional, event, and tournament-related communications, and providing personalized content or recommendations, with your consent where required by applicable law and subject to your communication preferences;
  • Cooperating with investigations when data is lawfully requested by judicial or administrative authorities.

3. Data Sharing, Transfer, and Public Disclosure Rules

We do not sell personal information for money. We disclose personal information only in the following limited circumstances:

Where you have provided your consent or directed us to disclose the information;

To affiliated companies for account administration, customer support, payment and tournament operations, analytics, security, fraud prevention, and anti-cheat risk control, subject to appropriate intra-group safeguards;

To service providers that assist us with hosting, cloud storage, payment processing, identity or age verification, geolocation verification, fraud prevention, anti-cheat services, customer support, analytics, crash monitoring, communications, marketing, advertising attribution, IT support, or information security. We require these providers to use personal information only for authorized purposes and in accordance with applicable law;

To advertising or analytics partners, where permitted by applicable law and subject to your consent or privacy choices, for analytics, advertising measurement, attribution, personalized content, or targeted advertising;

To third-party platforms or services, such as app stores, login providers, or payment providers, where necessary to provide a feature or transaction requested by you;

Where government authorities, courts, regulators, law-enforcement agencies, or tax authorities lawfully request the information, or where disclosure is otherwise required or permitted by applicable law;

Where reasonably necessary to protect the rights, property, or safety of users or others, prevent fraud or unlawful activity, enforce our agreements and tournament rules, or protect the security and integrity of the Services;

In connection with a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar corporate transaction, subject to appropriate confidentiality and data-protection safeguards.

We disclose only the personal information reasonably necessary for the applicable purpose.

The disclosure of advertising identifiers, device information, or Service activity information to advertising partners may be considered a “sale,” “sharing,” or processing for targeted advertising under certain privacy laws. Where required by applicable law, we will provide you with the right to opt out.

4. Data Storage, Retention, and Cross-Border Transfer Rules

4.1 Storage and Security Measures

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your personal information. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the Internet and that there is also some risk that others could find a way to thwart our security systems. If you believe that your personal information has not been handled in accordance with this Privacy Policy, please contact us using the contact details provided below.

4.2 Cross-Border Data Transfer Compliance

Where required, we use recognized transfer mechanisms and safeguards, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission, the UK International Data Transfer Addendum or Agreement, contractual protections, certifications, or regulatory approvals.

You may contact us to request information about applicable safeguards or a copy of relevant contractual protections, subject to necessary redactions.

We may use and transfer aggregated or anonymized information that does not reasonably identify an individual, subject to applicable law and contractual restrictions.

4.3 Data Processing After Account Cancellation

After you uninstall the software, stop using the Services, or request account cancellation, we will delete or anonymize personal information that is no longer necessary within a reasonable period.

We may retain personal information where continued retention is required or permitted by applicable law, or where necessary for purposes such as tax and accounting compliance, payment processing, fraud prevention, anti-cheat enforcement, tournament dispute resolution, identity verification, litigation, or the establishment, exercise, or defense of legal claims. The retained information will be deleted or anonymized when the applicable retention period expires or the relevant purpose no longer applies.

5. Your Complete Statutory Data Rights

You may submit a privacy rights request by contacting us at support@primewin.games. Subject to applicable law, we may request information reasonably necessary to verify your identity and authority before processing your request. You may also use an authorized agent to submit a request on your behalf where permitted by applicable law, although we may require proof of the agent’s authority and direct verification of your identity. Privacy rights requests are generally processed free of charge, but we may charge a reasonable fee or refuse to act on requests that are manifestly unfounded, excessive, or repetitive, where permitted by applicable law. Depending on your jurisdiction and subject to applicable exceptions, your rights may include:

  • Right of Access: Query all personal information, data usage, and sharing records we store about you;
  • Right to Rectification: Correct inaccurate or outdated identity, payment, and residential address information;
  • Right to Erasure (Right to Be Forgotten): Request account cancellation and deletion of all personal data;
  • Right to Withdraw Consent: Disable non-essential permissions such as photo album access, marketing push notifications, and advertising tracking at any time;
  • Right to Data Portability: Request a copy of your personal data in a machine-readable format;
  • Right to Restrict Processing: You may request restriction of processing of specific personal information within the scope permitted by applicable law. During the restriction period, we will continue, to the extent permitted by law, necessary data storage and processing required to fulfill legal obligations, protect legitimate interests, handle disputes, or prevent fraud;
  • Right to Object: Object to risk-control and tournament user profiling conducted based on our legitimate interests;
  • Right to Human Review of Automated Decisions: We may use automated tools, including profiling, to analyze device information, IP addresses, location signals, account activity, gameplay and tournament data, transaction information, and other risk indicators in order to detect fraud, cheating, multi-accounting, collusion, abnormal transactions, location spoofing, and other violations of our rules. Automated risk signals may result in temporary restrictions, delayed withdrawals, or referral for further review. We will not make a decision based solely on automated processing that produces legal or similarly significant effects on you unless the decision is necessary for the performance of a contract with you, is authorized by applicable law, or is based on your explicit consent. Where required by applicable law, you may request information about the decision, express your point of view, contest the decision, and request human review. We may require reasonable identity verification and supporting information before completing the review;
  • Right to Non-Discrimination: You have the right to be free from discrimination for exercising your privacy rights, including being offered different pricing or products, or receiving a different level or quality of the Services, based solely on your exercise of those rights;
  • Right to Lodge Complaints: You may lodge a complaint about our processing of your personal information with the competent data protection or privacy authority in your jurisdiction, where applicable.

Response Time Commitment

We will respond to verified privacy rights requests within the period required by applicable law. If we need additional time where permitted by law, we will notify you of the extension and the reason for it. If we deny a request in whole or in part, we will explain the reason for the denial and provide information about any available appeal or complaint process, unless applicable law permits or requires otherwise.

Supplementary Rights for U.S. Residents

Depending on the state in which you reside and subject to applicable legal exceptions, you may have the right to access, correct, delete, or obtain a copy of your personal information; obtain information about the categories, sources, purposes, and recipients of personal information; opt out of the sale or sharing of personal information, targeted advertising, or certain profiling; and appeal our refusal to process your request.

You have the right to be free from discrimination for exercising your applicable privacy rights. You or your authorized agent may submit a request by contacting us at support@primewin.games. We may take reasonable steps to verify your identity or the agent’s authority before processing the request.

6. Special Protection Rules for Minors' Personal Information

The Services are not directed to individuals under 18, and we do not knowingly collect personal information from anyone under 18.

Cash tournaments, paid competitions, cash-prize claims, withdrawals, and related identity-verification features are available only to individuals who are at least 18 and meet any higher minimum age required by applicable law.

If we learn that we have collected personal information from an individual under 18 contrary to applicable law, we will delete it promptly. A parent or guardian who believes that an individual under 18 has provided personal information to us may contact us at support@primewin.games.

Where applicable law imposes a higher minimum age or additional eligibility requirements, we will comply with those requirements.

7. Policy Update and Publication Mechanism

We may update this Privacy Policy to reflect changes in applicable laws, regulations, technologies, or our Services. The updated version will be posted through the Services or on our official website, and the “Updated” date will be revised accordingly;

Where required by applicable law, material changes will be communicated through an appropriate channel, such as an in-game notice, website notice, or registered email address, before the changes take effect;

The updated Privacy Policy will apply from its stated effective date. Where required by applicable law, we will obtain your consent before applying any material change to the processing of your personal information. Your continued use of the Services will not constitute consent where applicable law requires separate consent. If you do not agree with the updated Privacy Policy, you may stop using the Services and request cancellation of your account.

8. Contact, Complaints, and Regulatory Channels

If you have questions, objections, or complaints regarding this Privacy Policy or our data processing practices, you may contact us through the official customer service email. We will respond to and process your request within the statutory timeframe.

Email: support@primewin.games

Regulatory Complaint Channels

If you disagree with our data processing outcomes, you may, in addition to contacting us, file a complaint directly with the official data protection authority in your jurisdiction, including but not limited to: the Irish Data Protection Commission (DPC) for the EU, the California Privacy Protection Agency (CPPA), the Personal Information Protection Commission of Japan (PPC), the Personal Information Protection Commission of Korea (PIPC), the Singapore Personal Data Protection Commission (PDPC), and others.

9. Applicable Law and Dispute Jurisdiction

EU/UK Users: The processing of personal information is subject to the GDPR, the UK GDPR, the UK Data Protection Act 2018, and other applicable data-protection laws, as applicable;

U.S. Users: The processing of personal information is subject to applicable federal and state privacy laws;

Japan, Korea, Southeast Asia, and Other Regions: Applicable local personal information protection legislation applies;

Data-related disputes arising from this Privacy Policy should first be addressed through our customer service channels. Where permitted by applicable law, unresolved disputes may be subject to the dispute-resolution provisions of the User Service Agreement. Nothing in this section limits any non-waivable privacy right or your right to lodge a complaint with a competent regulatory authority.

10. Supplementary Disclaimers and Clarifications

The Services may contain links to third-party websites, applications, or services that we do not control. This Privacy Policy does not apply to those third parties. We encourage you to review their privacy policies and terms before providing personal information or using their services.