Privacy Policy

• 1

  Responsibility for data

  The platform provider is Koativa Tecnologia, Brazilian company registration 61.000.463/0001-48, at Avenida Cauaxi, 293, Sala 2903 C, Alphaville, Barueri, SP, CEP 06454-020. The privacy contact is pdjkleber@gmail.com. Each club’s role in processing depends on its decisions and activities; this does not remove Aceon’s responsibilities.

• 2

  Data processed

  The service processes registration and authentication data, preferences, club membership, game actions and histories, balances and transaction records. It may also process technical access and security logs. For identity checks, platform records include provider and decision references, amounts and dates related to the operation. This does not mean every account is verified or that the platform stores raw identity documents or biometric data.

• 3

  Accounts and service operation

  Registration, authentication, preference and participation data are used to create and maintain accounts and perform requested functions, based on performance of a contract or preliminary steps requested by the data subject. Data needed to process purchases and operations are also used for that purpose.

• 4

  Security, obligations and other purposes

  Abuse and fraud prevention may rely on legitimate interest following an assessment of necessity and balance with data subjects’ rights. Records required by a legal or regulatory obligation rely on that basis where the obligation actually applies. Data needed to defend rights may be processed for the regular exercise of rights. When a purpose requires consent, it must be specific, informed and revocable. These bases do not authorise indiscriminate use of all data.

• 5

  Access and sharing

  Depending on the feature used, necessary data may be accessed by the club and infrastructure, communication, payment or identity-verification providers. Authorities may receive information in circumstances permitted by law. Access should be limited to each recipient’s purpose and needs. Questions about recipients and purposes can be sent to the privacy contact.

• 6

  International transfers

  Providers processing data outside Brazil must be used in compliance with the LGPD and ANPD regulations, with a valid transfer mechanism, such as an applicable adequacy decision or contractual clauses established by the regulations. A similar law in another country is not sufficient on its own. You may request information about transfers applicable to your case from the privacy contact.

• 7

  Retention and account closure

  Account closure removes credentials and registration data. Transaction records, game histories and identity-verification records may remain. Closing an account does not automatically erase all these records. Retention needs a justified purpose, legal basis and period for each category, considering applicable obligations and the defence of rights. You may request information about retention periods and deletion where appropriate.

• 8

  Security and incidents

  Access controls and credential protection are used; no system removes every risk. Incidents must be assessed and, where legal criteria are met, reported to the ANPD and affected individuals within the deadlines and in the manner required by the LGPD and applicable regulations. Do not send passwords when requesting help.

• 9

  Your rights

  You may request confirmation of processing, access, correction, sharing information, portability under applicable regulations, and anonymisation, blocking or deletion in legally prescribed cases. You may withdraw consent, receive information about the consequences of withholding it, and object in cases provided by law. Under article 20 of the LGPD, you may also request review of decisions based solely on automated processing that affect your interests, and information about applicable criteria and procedures.

• 10

  Making a request

  Use pdjkleber@gmail.com to exercise your rights or ask about a decision. Proportionate identity confirmation may be requested to prevent improper disclosure. Responses must meet statutory deadlines and explain any inability to fulfil a request. You may also petition the ANPD and contact consumer-protection bodies. This policy describes a service in Brazil and does not claim worldwide legal validity.

• 11

  Minors and browser storage

  The platform is intended for people aged 18 or older. Report suspected use by a minor to pdjkleber@gmail.com / +55 (16) 98814-0687 for assessment and appropriate measures, including those concerning data. The Cookie Policy explains the storage used by the website. Material changes to this policy must be communicated clearly.

Updated September 13, 2026