Privacy Policy

versus International Inc. — Version 1.0 — September 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 never sell your personal data to third parties.

1. About This Policy

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

This Policy applies to:

• Our website www.versusapp.com
• Our mobile applications
• All prediction-market services we provide to customers resident outside the United Kingdom
• All communications between you and us

If you are resident in the United Kingdom, your services are provided by versus Inc. under its own Privacy Policy, which is shown to you instead. Where personal data is shared between the two companies (Section 6.4), each company is responsible for its own processing.

By using our Services, you acknowledge that you have read and understood this Privacy Policy.

Updates

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

2. Who We Are

2.1 Data Controller

versus International Inc. 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, verify your identity, use the 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:

Blockchain data is public. Your wallet address and its transactions are recorded on a public blockchain that anyone can read and that we do not control. We link that public data to your Account in order to provide the Services.

3.3 Information from Third Parties

We receive information about you from:

• Sumsub — identity verification, document checks, liveness results, and sanctions and PEP screening results
• Our wallet-infrastructure provider — the wallet address created for you and the status of any permission you grant
• Payment providers you use to buy or sell USDC — confirmation that a transaction to or from your wallet has taken place; the provider processes your payment details itself
• Fraud-prevention and screening services — sanctions lists, politically exposed person (PEP) data and fraud indicators
• Public blockchain networks — the public record of your wallet's transactions

3.4 Special Categories of Data

We may process "special category" data in limited circumstances, for example biometric data derived from your selfie during identity verification (processed by Sumsub for verification only) and health or vulnerability information if you disclose it to us in connection with player protection.

Sensitive Data

We only process special category data where it is necessary to verify your identity, to protect your wellbeing, to comply with a legal obligation 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 and connecting your wallet
• Displaying Markets, executing the Positions you place and showing your history
• Communicating with you about your Account and your Positions
• Providing customer support

4.2 Legal and Regulatory Compliance

• Verifying your identity, age and country of residence
• Screening against sanctions lists and for PEP status before and during your use of the Services
• Conducting anti-money-laundering and counter-terrorist-financing checks
• Detecting and preventing fraud, market manipulation and other crime
• Meeting the requirements of our providers and of the laws that apply to us
• Responding to lawful requests from regulators, courts and law enforcement

4.3 Player Protection

• Applying the limits, breaks and exclusions you set
• Monitoring activity for signs that our Services may be causing harm
• Honouring exclusions across our corporate group

4.4 Improving Our Services

• Analysing how customers use our Services
• Developing, testing and improving features and technology
• Ensuring the security and stability of the platform

4.5 Marketing (With Your Consent)

• Sending you news, offers and information about new Markets and features
• Measuring the effectiveness of our advertising, where you have consented to it

Marketing Control

You can opt out of marketing at any time in your Account settings or by using the unsubscribe link in any marketing email. You will still receive service and legal communications.

4.6 Protecting Our Business

• Enforcing our Terms & Conditions
• Detecting and preventing abuse of our Services
• Establishing, exercising or defending legal claims

5. Legal Bases for Processing

We rely on the following legal bases:

6. Who We Share Your Information With

6.1 Service Providers

We share information with providers who help us operate our Services:

Our service providers process data on our instructions and are contractually required to protect it.

6.2 Independent Controllers

The following recipients decide for themselves how they process your data and are responsible for it under their own privacy policies:

• Payment providers you use to buy or sell USDC. They are the merchant of record for your payment, collect your payment details directly and carry out their own verification. We never receive your card or bank details.
• Public blockchain networks, where your wallet address and transactions are recorded permanently and publicly.

6.3 Regulators and Authorities

We may share information with regulators, financial-intelligence units, courts, tax authorities and law enforcement where the law requires or permits it, and with sports governing bodies and integrity services where we detect suspected manipulation.

6.4 Our Corporate Group

versus International Inc. and versus Inc. share limited data with each other to enforce one Account per person, to honour self-exclusions across the group, and for compliance and fraud prevention, under written intra-group data-protection arrangements.

6.5 What We Never Do

We Never

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

7. International Data Transfers

We store your data on servers located in the United Kingdom. Some of our providers are located in, or process data in, other countries, including the United States and countries in the European Economic Area.

7.1 Safeguards

When data is transferred outside the Isle of Man, the United Kingdom or the European Economic Area, we rely on:

• Adequacy decisions — transfers to countries recognised as providing adequate protection
• Standard Contractual Clauses and equivalent approved transfer tools
• Written intra-group arrangements for transfers within our corporate group
• Your explicit consent, where no other safeguard is available

Your Right to Know

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

8. How Long We Keep Your Information

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

Blockchain records cannot be deleted. Transactions recorded on a public blockchain are permanent by design. When you exercise a right to erasure, we delete or anonymise the data we hold and unlink your Account from your wallet address, but the public blockchain record itself remains.

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

9. Your Rights

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

9.1 How to Exercise Your Rights

Contact our Data Protection Officer at dpo@versusapp.com. We respond within one month. You can also download your data and request deletion of your Account in the app under Settings.

9.2 Complaints

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

10. Cookies and Similar Technologies

10.1 What We Use

We use cookies and similar technologies (such as local storage on your device) to keep you signed in, keep the Services secure, remember your preferences, understand how the Services are used and, only with your consent, measure advertising.

10.2 Managing Cookies

You can control non-essential cookies through the consent choices we show you, in your Account settings under Privacy and through your browser settings. Blocking essential cookies may prevent you from using the Services.

11. Compliance-Specific Processing

11.1 Identity and Age Verification

We are required to verify that every customer is at least 18 years old (or older where local law requires) and is who they say they are, before they can open a Position or move funds through the Services. We use Sumsub to verify identity documents and to perform a biometric liveness check.

11.2 Sanctions and PEP Screening

We screen every user against sanctions lists and for politically exposed person status before first use and periodically afterwards. A match may lead us to ask you for information, to restrict your Account or to decline the Services.

11.3 Anti-Money Laundering

We carry out customer due diligence, enhanced due diligence for higher-risk customers, source-of-funds checks where required and transaction monitoring, and we report suspicious activity to the relevant authorities.

Legal Requirement

This processing is required by law and by our providers. We cannot provide the Services without it.

11.4 Player Protection Monitoring

We monitor activity for signs that our Services may be causing harm, including frequency and duration of use, changes in behaviour, amounts committed and use of protection tools.

11.5 Market Integrity

We monitor for manipulation, insider activity and collusion and may share information with sports governing bodies and integrity services where we detect suspicious patterns.

11.6 Automated Decision-Making and Profiling

We use automated systems to verify identity, screen for sanctions, detect fraud and unusual activity and monitor for player-protection purposes. These systems may trigger requests for information, limits or restrictions on your Account. We do not make decisions based solely on automated processing that produce legal or similarly significant effects on you without a meaningful possibility of human review. You may request human intervention, express your point of view and contest such a decision by contacting dpo@versusapp.com.

12. Children's Privacy

Our Services are strictly for adults. We do not knowingly collect personal information from anyone under 18, or under the higher minimum age that applies where they live. If we discover that we hold such information, we will close the Account, delete the personal information except for the limited record the law requires us to keep, and report the matter to the relevant authorities where required. 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 to reflect changes in our practices, technology, providers or legal requirements. If we make material changes, we will notify you by email to your registered email address or through a prominent notice in the app, give you reasonable time to review the changes and, where required, ask for your consent.

14. Contact Us

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

We're Here to Help

We take your privacy seriously. If you have any questions about how we use your data, please contact us.

— End of Privacy Policy — Version 1.0 — September 2026