Privacy Policy

Version 1.5 — August 2026 (supersedes Version 1.4 — March 2026)

Our Privacy Promise

Your personal information belongs to you. We are committed to protecting your privacy, being transparent about how we use your data, and giving you control over your information. We will always keep your data safe and never sell it to third parties for their own marketing purposes.

1. About This Policy

This Privacy Policy explains how versus Inc., trading as "versus" ("we", "us", "our", "versus"), collects, uses, shares, and protects your personal information when you use our betting services.

This Policy applies to:

• Our website www.versusapp.com
• Our mobile applications
• All betting services we provide
• All communications between you and us

By using our Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Policy, please do not use our Services.

Updates

We may update this Policy from time to time. If we make material changes, we will notify you via email or through our app before the changes take effect.

2. Who We Are

2.1 Data Controller

versus is the "data controller" for your personal information, meaning we determine how and why your data is processed.

2.2 Data Protection Officer

We have appointed a Data Protection Officer (DPO) to oversee our data protection practices.

3. Information We Collect

3.1 Information You Provide Directly

When you register for an account, use our services, or contact us, you provide us with personal information including:

3.2 Information We Collect Automatically

When you use our Services, we automatically collect:

3.3 Information from Third Parties

We may receive information about you from third parties including:

• Sumsub — identity and age verification
• Credit-reference and public-record providers — for regulatory financial-vulnerability checks (soft searches only, no

impact on your credit score)

• Fraud prevention services — to detect and prevent fraud
• GAMSTOP — to check self-exclusion status
• Nuvei — to process deposits, withdrawals and payment transactions
• Xace — to provide the designated customer-funds account and related banking services
• Publicly available sources — electoral roll, social media, insolvency registers

3.4 Special Categories of Data

In certain circumstances, we may process "special category" data including:

• Health information — if you disclose gambling-related harm or health conditions
• Financial vulnerability — if you indicate financial difficulties

Sensitive Data

We only process special category data when necessary to protect your wellbeing, comply with responsible gambling obligations, or where you have given explicit consent. We never use this data for marketing.

4. How We Use Your Information

4.1 Providing Our Services

• Creating and managing your account
• Processing bets, deposits, and withdrawals
• Displaying your betting history and account balance
• Communicating with you about your account
• Providing customer support

4.2 Legal and Regulatory Compliance

• Verifying your identity and age (you must be 18+)
• Conducting anti-money laundering (AML) checks
• Verifying source of funds
• Checking GAMSTOP and self-exclusion registers
• Monitoring for responsible gambling
• Detecting and preventing fraud and crime
• Complying with Gambling Commission requirements
• Reporting to regulators and law enforcement when required

4.3 Responsible Gambling

• Monitoring your betting activity for signs of problem gambling
• Implementing deposit limits and cooling-off periods you request
• Conducting affordability assessments
• Sending responsible gambling reminders
• Providing self-exclusion tools

4.4 Improving Our Services

• Analysing how customers use our Services
• Developing new features and products
• Testing and improving our technology
• Conducting market research

4.5 Marketing (With Your Consent)

• Sending promotional offers and bonuses
• Informing you about new features and markets
• Personalising your experience based on your preferences

Marketing Control

You can opt out of marketing at any time via your account settings (Notifications) or by clicking 'unsubscribe' in any marketing email. You will still receive transactional and regulatory communications.

4.6 Protecting Our Business

• Enforcing our Terms & Conditions
• Detecting and preventing abuse of our Services
• Managing our commercial risk
• Pursuing or defending legal claims

5. Legal Bases for Processing

Under data protection law, we must have a valid legal basis for processing your personal information. The legal bases we rely on are:

bets)

Legal Obligation — Processing required by law (e.g., AML checks, age verification, Gambling Commission

requirements)

Legitimate Interests — Processing necessary for our legitimate business interests, where not overridden by your rights

(e.g., fraud prevention, improving services)

Consent — Where you have given clear consent for us to process your data for a specific purpose (e.g.,

marketing)

Vital Interests — Where processing is necessary to protect your life or wellbeing (e.g., urgent responsible

gambling intervention)

6. Who We Share Your Information With

6.1 Service Providers

We share information with trusted third parties who help us operate our Services:

All service providers are contractually required to protect your data and can only use it for the specific purposes we instruct.

6.2 Regulators and Authorities

We may share information with:

• Gambling Commission — regulatory compliance and reporting
• GAMSTOP — self-exclusion register
• Law enforcement — when required by law or to prevent crime
• Tax authorities — HMRC and equivalent in other jurisdictions
• Sports governing bodies — betting integrity issues
• Other gambling operators — multi-operator self-exclusion

6.3 What We Never Do

We Never

Sell your personal information to third parties. Share your data with third parties for their own marketing purposes without your explicit consent. Use special category data for marketing.

7. International Data Transfers

Your personal information may be transferred to, and processed in, countries outside your country of residence. This may include countries that do not have data protection laws equivalent to those in the UK or EU.

7.1 Safeguards

When we transfer data internationally, we implement appropriate safeguards:

• Standard Contractual Clauses (SCCs) approved by the UK/EU
• Adequacy decisions — transfers to countries deemed to have adequate protection
• Binding Corporate Rules — for transfers within corporate groups
• Your explicit consent — where other safeguards are not available

Your Right to Know

You can request information about the safeguards we use for international transfers by contacting our DPO.

8. How Long We Keep Your Information

We keep your personal information only as long as necessary for the purposes for which it was collected, or as required by law.

regulatory obligations

Complaints — 6 years after resolution

When we no longer need your data, we securely delete or anonymise it. Anonymised data may be retained for analytics and research purposes.

9. Your Rights

You have rights over your personal information. These rights may vary depending on your location, but generally include:

9.1 How to Exercise Your Rights

To exercise any of your rights, please contact our Data Protection Officer at dpo@versusapp.com. We will respond within one month.

9.2 Complaints

If you are unhappy with how we handle your personal information, you have the right to complain to a data protection authority:

10. Cookies and Tracking Technologies

10.1 What Are Cookies?

Cookies are small text files stored on your device when you visit our website. They help us recognise you, remember your preferences, and improve your experience.

10.2 Types of Cookies We Use

10.3 Managing Cookies

You can control cookies through:

• Our cookie consent banner — shown when you first visit
• Your browser settings — to block or delete cookies
• Our cookie settings page — to update your preferences

Note: that blocking essential cookies may prevent you from using our Services.

10.4 Cookie Policy

For more detailed information about the specific cookies and similar technologies we use, please see our separate Cookie Policy, which is available on our website and app.

11. Gambling-Specific Data Processing

As a licensed gambling operator, we have specific obligations regarding how we process your data.

11.1 Age and Identity Verification

We are legally required to verify that all customers are 18 or older. We use identity verification services to check your age and identity before you can deposit or bet.

11.2 GAMSTOP

versus participates in GAMSTOP, the UK's national self-exclusion scheme. We check all new registrations and periodically re-check existing customers against the GAMSTOP database.

GAMSTOP Data

When you register with GAMSTOP, your data is shared with all licensed UK gambling operators to prevent you from gambling. Learn more at www.gamstop.co.uk. Please note, this is for your safety.

11.3 Responsible Gambling Monitoring

We monitor your betting activity for signs of problem gambling. This may include:

• Frequency and duration of betting sessions
• Changes in betting patterns
• Deposit and loss amounts relative to affordability
• Time of day gambling occurs
• Use of responsible gambling tools

11.4 Anti-Money Laundering

We are required to conduct AML checks including:

• Customer due diligence (CDD) — verifying your identity
• Enhanced due diligence (EDD) — for higher-risk customers or transactions
• Source of funds checks — verifying where your money comes from
• Transaction monitoring — detecting suspicious patterns
• Reporting suspicious activity to the National Crime Agency (NCA)

Legal Requirement

AML processing is required by law. We cannot provide gambling services without conducting these checks. It also allows us to keep versus fair and safe for everyone.

11.5 Affordability Checks

We may conduct affordability checks using credit reference agencies (such as Experian). These are typically "soft" checks that do not affect your credit score. We use this information to ensure that gambling is affordable for you as part of our responsible gambling obligations. You can find more information about how Experian uses and shares personal data in their privacy notice at experian.co.uk.

11.6 Betting Integrity

We may share information with sports governing bodies and integrity services if we detect suspicious betting patterns that may indicate match-fixing or other integrity issues.

11.7 Automated Decision-Making and Profiling

We use automated systems and profiling to help us meet our legal and regulatory obligations and to protect you and our business. This includes using automated tools to:

• Carry out identity, fraud and anti-money laundering checks
• Monitor betting patterns for responsible gambling purposes
• Assess affordability (using information from credit reference agencies)
• Detect unusual or suspicious activity on your account

These automated processes may affect the services we can offer you. For example, they may trigger requests for additional information, apply limits or restrictions to your account, or, in some cases, lead to the suspension or closure of your account.

We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you without a meaningful possibility of human review.

Where we do rely on automated processing in this way, you have the right to:

• Request human intervention
• Express your point of view
• Contest the decision

Exercise Your Rights

You can exercise your rights regarding automated decision-making by contacting our Data Protection Officer at dpo@versusapp.com.

12. Children's Privacy

Our Services are strictly for adults aged 18 and over. We do not knowingly collect personal information from anyone under 18.

If we discover that we have collected information from a person under 18:

• We will immediately close the account
• Void all transactions
• Return any deposits
• Delete the personal information, except for a limited record we may retain where necessary to

comply with our legal and regulatory obligations (for example, to demonstrate that we prevented underage gambling and to prevent further attempts to open an account)

• Report the matter to relevant authorities if required
• Block your device
• Banning you for lifetime

If you believe a child has registered with us, please contact us immediately at support@versusapp.com.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons.

If we make material changes, we will:

• Notify you by email to your registered email address
• Display a prominent notice in our app
• Give you reasonable time to review the changes
• Where required, obtain your consent to the new terms

14. Contact Us

If you have any questions regarding this Privacy Policy or how we handle your personal information:

IM1 2QA

We're Here to Help

We take your privacy seriously. If you have any questions about how we use your data, please don't hesitate to contact us.

Appendix A: United Kingdom

For UK customers, this Privacy Policy is made in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

• Data Controller: versus Inc.
• Supervisory Authority: Information Commissioner's Office (ICO)
• ICO Website: ico.org.uk
• ICO Helpline: 0303 123 1113

— End of Privacy Policy — Version 1.5 — August 2026