Privacy Notice Effective Date: July 7, 2025 FELLAWAY LIMITED (hereinafter referred to as “we,” “us,” “our,” or the “Company”) respects your privacy and strives to protect your personal data. We aim to make the use of this website (“Website”) as convenient and safe as possible. This Privacy Notice (hereinafter referred to as the “Notice”) describes how we collect, use, disclose, retain, and protect personal data obtained through this Website. Where applicable laws are stricter than the practices described in this Notice, FELLAWAY LIMITED has adopted specific privacy practices in those regions to meet the stricter requirements. 1. CONTROLLER INFORMATION For the purposes of the GDPR and other applicable data protection or data privacy laws, the Data Controller is: FELLAWAY LIMITED Georgiou Griva Digeni, 113 Astromeritis, 2722, Nicosia, Cyprus Email: support.web@fellawaygame.com Data processing is carried out by us solely for the purposes defined in this Notice. Please note that you have the right to withdraw consent at any time, in the manner specified in this Notice. 2. WHO THIS NOTICE APPLIES TO This Notice applies to: Website Visitors Individuals who browse and interact with our Website. Job Applicants Candidates applying for positions at FELLAWAY LIMITED. Partners’ Employees Employees, directors, or other authorized individuals associated with our business partners and vendors, where personal data is shared with us in the context of professional relationships. Contest Participants Individuals who enter or participate in contests or promotions on our Website, where personal data might be collected and processed under specific rules or terms. If you engage with any of our FELLAWAY LIMITED Projects or mobile games, please note they may have separate and specific privacy policies. 3. DATA WE PROCESS 3.1 Website Visitor We generally do not collect personal data about casual visitors to our Website unless you choose to provide it (e.g., by filling out a contact form, subscribing to newsletters, or sending us an email). Some data may be collected automatically via cookies or similar technologies (see Section 6 below). If you contact us, we may keep a record of that correspondence, including your name, email address, and any additional information you provide. 3.2 Job Applicants When you apply for an open position at FELLAWAY LIMITED, we may collect personal data such as: Name, contact details (email, phone number), address; CV/resume, cover letter, LinkedIn profile; Previous work experience, skills, and education details; Professional licenses or certifications; References or background check details (where legally permissible). We collect and process this data to evaluate your application, communicate with you throughout the hiring process, and potentially extend a job offer. 3.3 Contest Participants If you enter a contest or promotion organized by FELLAWAY LIMITED, we may collect the personal data necessary to administer the contest (e.g., name, email, and potentially shipping address for prizes). Such data will be processed according to the specific contest rules and only with your consent, where required. 3.4 Employees of Partners We may collect personal data about employees, directors, and authorized signatories of FELLAWAY LIMITED’s corporate partners, business customers, or vendors. This may include: Name, job title, work address; Corporate email address, phone number; Any other information necessary for business communication or collaboration. 4. PURPOSE OF DATA PROCESSING We process personal data for the following purposes: Website Functionality To respond to inquiries, provide requested information, and improve the user experience. Recruitment To process and evaluate job applications, conduct interviews, and possibly make employment offers. Contest Administration To manage any contests or promotions, contact winners, and deliver prizes where applicable. Partner & Vendor Relations To communicate and collaborate with our corporate partners, manage contracts, and maintain business relationships. Compliance & Legal Obligations To comply with applicable laws, regulations, legal processes, or enforceable governmental requests. Legitimate Interests To protect our rights, property, or safety; to prevent fraud or illegal activities; to conduct analytics on Website usage for improvement (subject to your consent where required by law). 5. LEGAL BASES FOR PROCESSING (GDPR) Where the General Data Protection Regulation (GDPR) applies, we rely on the following legal bases: Consent (Art. 6(1)(a) GDPR): For activities such as newsletter subscriptions or certain optional cookies. Contract (Art. 6(1)(b) GDPR): Where data processing is necessary to fulfill a contract or recruitment process at your request. Legal Obligation (Art. 6(1)(c) GDPR): Where we must comply with legal or regulatory requirements. Legitimate Interests (Art. 6(1)(f) GDPR): Where we process data to protect our rights, improve our services, or for other justifiable business interests, taking into account your interests and fundamental rights. 6. COOKIES AND SIMILAR TECHNOLOGIES We may use cookies, web beacons, or similar technologies to: Recognize your device and save your preferences (e.g., language); Analyze traffic and user interactions on the Website; Deliver relevant advertisements or content (if applicable). Cookie Types: Strictly Necessary Cookies: Essential for the Website to function (cannot be disabled). Analytics / Performance Cookies: Help us measure and improve the performance of our Website. Functionality Cookies: Enhance Website features, remember settings. Targeting / Advertising Cookies (if used): Deliver relevant ads to you. You can control or disable cookies via your browser settings. However, certain features of our Website may not function properly if cookies are disabled. For more details, please review our separate Cookie Policy (if provided). 7. SHARING YOUR DATA WITH THIRD PARTIES We do not sell your personal data. In order to provide our Services, we may share your data under the following circumstances: Service Providers Cloud hosting, analytics, customer support, or recruitment software providers. They are contractually obligated to keep your data confidential and comply with applicable data protection laws. Affiliates & Group Companies We may share data with affiliated entities within FELLAWAY LIMITED if needed for business operations, provided that they uphold an equivalent level of data protection. Legal or Regulatory Disclosures When required by law, regulation, or legal process, or to protect our rights, property, or the safety of users or the public. Business Transfers In cases of mergers, acquisitions, or sale of assets, user data may be transferred as part of the transaction, subject to confidentiality agreements. 8. INTERNATIONAL DATA TRANSFERS FELLAWAY LIMITED is an international company, and your data may be processed in countries outside your place of residence. If such transfers occur from the European Economic Area (EEA) or other regions with strict data transfer laws, we take measures to ensure an adequate level of data protection, such as Standard Contractual Clauses (SCCs) or other recognized legal mechanisms. If you have questions about international data transfers or wish to obtain a copy of the safeguards, please contact us at support.web@fellawaygame.com. 9. DATA RETENTION We retain personal data only as long as necessary for the purposes outlined in this Notice or as required by law. For example: Website Inquiries: Data may be kept until we have responded to your request and for a reasonable period thereafter. Job Applications: Data is typically retained until the recruitment process is concluded. If we consider you for future positions, we may store your data longer unless you object. Contest Data: Stored for the duration of the contest and any legal holding period (e.g., tax or prize claim validations). Partner Data: Held as long as needed for the business relationship or as legally required. Once the data is no longer necessary, it is either deleted or anonymized. 10. DATA SECURITY AND PROTECTION We take technical and organizational measures to protect your data, including: Encryption: During transmission and/or at rest, where feasible; Access Controls: Limiting access to personal data to authorized personnel only; Security Assessments: Regularly checking systems and processes for vulnerabilities; Internal Policies and Training: Ensuring employees understand their data protection obligations. However, no method of data transmission or storage is 100% secure. You are responsible for keeping any account details confidential. 11. YOUR RIGHTS AND DATA MANAGEMENT Depending on your jurisdiction, you may have the following rights: Withdraw Consent: At any time, where processing is based on consent. Access: Request information about data storage and copies of your personal data. Rectification: Correct or update inaccurate data. Erasure (“Right to be Forgotten”): Request deletion of personal data under certain conditions. Restrict Processing: Temporarily limit data processing in certain scenarios. Object: If you believe we have no legitimate reason for processing your data. Data Portability: Receive your data in a structured format, in certain circumstances. Complaint: Lodge a complaint with a local supervisory authority if you believe your rights have been infringed. To exercise these rights, please contact us at support.web@fellawaygame.com. We typically respond within 30 days or the timeframe mandated by local law. 12. LOCAL LEGISLATION We provide our Website and services worldwide and strive to comply with applicable local laws. By continuing to use the Website, you warrant that your use does not contravene any local legal requirements or our Terms of Service. Where local law requires stricter privacy practices, FELLAWAY LIMITED implements them accordingly. We do not sell personal data for profit in any jurisdiction, including under California law. Transfers of data (if any) are carried out only as necessary to provide our Services lawfully. 13. CHANGES TO THIS NOTICE We reserve the right to modify or update this Privacy Notice at any time, so please review it periodically. Material changes will be posted on this page or otherwise notified to you. The “Effective Date” at the top indicates when the latest version took effect. 14. CONTACT DETAILS OF THE DATA PROTECTION MANAGER If required or applicable, FELLAWAY LIMITED may appoint a Data Protection Manager or Data Protection Officer. For now, you may direct any inquiries or requests to: FELLAWAY LIMITED – Data Protection Manager Georgiou Griva Digeni, 113 Astromeritis, 2722, Nicosia, Cyprus Email: support.web@fellawaygame.com If your consent expires, is withdrawn, or is otherwise canceled, we will delete the data processed on the basis of that consent, unless another legal basis allows or requires continued processing (e.g., legal obligations, contractual necessity). 15. FINAL PROVISIONS This Privacy Notice is made in the English language. In case of any inconsistencies or discrepancies between a non-English translation and the English version, the English version shall prevail. By using the Website, you confirm that you have read, understood, and agree to the terms of this Notice. FAITHFULLY YOURS, FELLAWAY LIMITED