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Consent form for the transfer of bettors' data and resources

  1. Identification of the Parties

    Alpha Games N.V., under licence from the Commercial Registry of the Chamber of Commerce and Industry of Curaçao (Heelsumstraat 51, Willemstad, Curaçao, PO Box 3075, Willemstad, Curaçao), established in Curaçao, regulated and with a valid licence from the Curaçao Gaming Control Board, number 8048/JAZ2019-020, hereinafter referred to as the "Sender Legal Entity", and Futuras Apostas LTDA, registered with the CNPJ under no. 55.399.607/0001-88, with registered office at Rua Prof. Atílio Innocenti, 165, Andar 5, Sala 05-120, Conjuntos 201, 301, 401, 501, 601 e 701, Vila Nova Conceição, São Paulo/SP, CEP 04538-000, hereinafter referred to as the "Receiving Legal Entity", request this consent from the data subject.

  2. Definitions

    To better understand this Consent Form, here are some explanations of the terms used, in accordance with SPA/MF Ordinance No. 1,857/2024:

    • Transfer of data and resources: this is the sending of your information and amounts registered with Alpha Games N.V. (sender) to Futuras Apostas Ltda. (receiver), which is part of the same economic group.
    • Sender Legal Entity: is the company Alpha Games N.V., which currently operates and where its data and resources are registered.
    • Receiving Legal Entity: is the company Futuras Apostas Ltda., which has requested authorisation to operate in Brazil and will receive your data and resources to continue offering betting services.

  3. Purpose of the transfer

    We are working to ensure that you continue to use our services without interruption. 's why, in light of the new Brazilian regulations, we need to transfer your personal data, balance and open bets to the new operation in Brazil. This ensures that your bets remain active and you have access to your money in a safe and practical way, following the rules defined by Ordinance No. 1,857 of 25 November 2024.

    This Agreement explains how this transfer will take place and the necessary steps. By accepting, you are authorising the actions described below.

  4. Data and Resource Transfer

    You authorise the transfer of the following items from your current account to the new Brazilian platform:

    • Your registration data (such as full name, username, date of birth, password, cpf, images sent by the user for any purpose, records (logs) of interactions at all levels of support, acceptance or refusal of any terms, updates or changes to user information, additions or modifications to bank accounts, complete KYC records, all documents and information collected through the KYC process, records and proof of deposits in cases where KYC was not accepted and a withdrawal request was made, facial biometrics;
    • Your contact details (such as e-mail, telephone and full address);
    • Your financial details (such as the amounts you have in your current account, currency used, deposits, withdrawals, registered bank account information);
    • Your open bets, if any (such as your betting history, financial contributions and withdrawals history, winnings and losses history, commissions, other credits and debits that may form part of your financial history, detailed financial transactions and account access history);
    • Data that is relevant to the provision of BRAZINO777 services.

    This transfer will be carried out securely and will allow you to access your new account using the same current registration. However, it is important to clarify that, alternatively, you can choose:

    • Authorise the transfer to BRAZINO777.
    • Withdraw the amounts from your account.
    • Cancel your open bets with a full refund of the amount wagered.

    The transfer will only take place with your consent.

  5. Opening a Bank Account in Brazil

    The identity verification process ("KYC") is a necessary step carried out by BRAZINO777 to ensure that your information is secure and complies with Brazilian law. KYC includes the validation of identification documents such as ID, CNH, Passport, Professional Registration, CPF, among others. It will also involve the use of biometric authentication, such as facial recognition, to protect your transactions and ensure that your account complies with regulations.

    It will work follows:

    To operate on the new platform, you must complete the identity verification (KYC) process in order to have an account considered active and to be eligible for the incentive set out in item 8 below. This procedure involves verification of:

    • Personal details;
    • Bank details;
    • Contact details;
    • Access and geolocalisation data.

    All information will be protected in accordance with the LGPD and other applicable regulations, ensuring your privacy and security.

    After this procedure, you will authorise the transfer of data in the KYC process to BRAZINO777 for the purpose of opening an account.

    The KYC process will include biometric authentication to guarantee the security of your data and to confirm your identity.

  6. Creating an account with Operação Brasil

    After accepting these terms, your player account will be created automatically and considered active after KYC validation. You authorise the transfer of the balance held in your Curaçao account to the new transactional account in Brazil.

  7. Transfer deadline

    Once the transfer process has been successfully completed, you will have full access to the new account and services in Brazil.

    However, it is important to note that you have until 31/03/2025 to consent to the transfer of your data and funds to BRAZINO777, and if you do not do so by that date or if you indicate your refusal, you must: (a) withdraw the funds belonging to you by sending them to one of your accounts registered with a financial or payment institution authorised by the Central Bank of Brazil or (b) authorise the transfer of the funds belonging to you to a transactional account with the Receiving Legal Entity, with the respective registration in the graphic account; (c) cancel the bets, with a full refund of the amount wagered and returned or, (d) keep the bet, which will be held on the platform of the Receiving Legal Entity.

  8. Exclusive Incentive

    To encourage you to stay with us and migrate from Platforms to BRAZINO777 without having to make a withdrawal, you can receive an exclusive loyalty incentive.

  9. Important

    To guarantee your continuity and obtain exclusive benefits for belonging to the BRAZINO777 user network:

    • Complete the KYC process.
    • Accept this Term until 31/03/2025.

  10. Data destination

    If you successfully accept, your data will be transferred to Brazil, where it will be processed and stored in accordance with national data protection laws, and in accordance with Law 14.790/2023 and Ordinances issued by the Ministry of Finance/Secretariat of Prizes and Betting.

  11. Data Protection

    The Sender and Receiver Legal Entities undertake to adopt all necessary measures to ensure the protection of your personal data, in accordance with the LGPD, and Resolution CD/ANPD No. 19/2024 and other general and sectoral rules of the legislation in force in the country of destination. This includes, but is not limited to, the adoption of information security and privacy protection mechanisms and the implementation of standard contractual clauses approved by the ANPD, ensuring that your data is treated with the level of protection required by the regulations and best market practices.

    In this regard, the Sending and Receiving Legal Entities undertake to observe the following aspects in relation to the transfer of personal data and resources, in accordance with Brazilian legislation and SPA/MF Ordinance No. 1,857/2024:

    • Check the general and sectoral legislation in force in the country of destination;
    • Consider the sensitivity and nature of the data transferred, adopting proportionate measures to protect it;
    • To ensure compliance with the general principles of personal data protection and the rights of data subjects, as established in the General Data Protection Act (LGPD);
    • Implement appropriate technical and organisational security measures, in compliance with applicable regulations, to prevent unauthorised access and security incidents;
    • Make sure that there are judicial and institutional mechanisms in the country of destination or international organisation that ensure that personal data protection rights are respected;
    • Ensure that the identification and registration of punters by the Sending Legal Entity complies with the provisions of SPA/MF Ordinance No. 722, of 2 May 2024, and SPA/MF Ordinance No. 1,231, of 31 July 2024;
    • Ensure that the data transferred to the Receiving Legal Entity is stored and processed in accordance with the rules set out in SPA/MF Ordinance No. 722 of 2 May 2024;
    • Allow each punter's funds to be duly identified by both the Sending Legal Entity and the Receiving Legal Entity, using the Individual Taxpayer Registration number (CPF) as the main identifier;
    • During the period of transfer of data and resources, the Sender Legal Entity may maintain its own platform exclusively for the purposes of exercising the rights dealt with in Items J to M of "Item 12. Rights of the Personal Data Subject", and is prohibited from offering new products or services, including betting, after 31 December 2024;
    • Bets that are still open at the Sender Legal Entity on 28.02.2025 must be closed on that date, with the full amount wagered transferred to the bettor's transactional account, with the respective entry in the printing account.

  12. Contact for exercise of rights and questions

    If you have any doubts, questions or concerns regarding these Terms, or if you wish to exercise your rights as a rights holder, you can contact us at [email protected].

  13. Additional Technical Information

    Funds held by bettors in transactional accounts with the sending legal entities that have not been withdrawn or transferred under the terms of Ordinance No. 1,857/2024 by 31 March 2025 will be transferred to the deposit or payment account registered by the bettor with the Sending Legal Entity and recorded in the Receiving Legal Entity's accounting balances.

    If the punter does not have a deposit or payment account registered with the Sender Legal Entity, a transfer may be made to the deposit or payment account through which the punter made the last financial contribution on the Sender Legal Entity's platform, provided that it is possible to identify that the punter is the actual account holder.

    In the event that it is not possible to remit the funds in accordance with Ordinance No. 1,857/2024, including due to problems involving the punter's deposit or payment account, the impossibility of contacting them or their refusal to indicate a bank or payment account, the Receiving Legal Entity will carry out the following actions between 1st April 2025 and 30th June 2025:

    • It will keep the accounting records of the funds mentioned in Ordinance No. 1,857/2024;
    • It will endeavour to contact players so that they can indicate a deposit or payment account they hold with an institution authorised by the Central Bank of Brazil, through which they can receive the funds they hold.

    The funds not remitted to the bettors in the form of Ordinance No. 1,857/2024 by 30 June 2025 will be reverted to the Student Financing Fund - Fies and the National Fund for Public Calamities, Protection and Civil Defence - Funcap, in form of art. 32, § 1, of Law No. 14,790, of 29 December 2023.

  14. Declaration of Consent

    BY CLICKING ON THE "ACCEPT AND CONTINUE" BUTTON BELOW, YOU DECLARE THAT:

    • HAS READ, UNDERSTOOD AND AGREES TO THE TERMS OF THIS DOCUMENT;
    • FREELY, INFORMEDLY AND UNEQUIVOCALLY AUTHORISES THE TRANSFER OF THEIR PERSONAL DATA AND RESOURCES TO THE RECEIVING LEGAL ENTITY, UNDER THE TERMS SET OUT HEREIN;
    • RECOGNISES THAT THIS TERM BECOMES PART OF THE SERVICE CONTRACT FOR THE PLATFORM OF THE RECEIVING LEGAL ENTITY, BINDING ITSELF TO THE CONDITIONS OF USE AND OPERATION ESTABLISHED ON THE NEW PLATFORM;
    • YOU BEEN INFORMED THAT CONSENT IS OPTIONAL AND CAN BE REVOKED AT ANY TIME, UNDER THE TERMS OF THE GENERAL DATA PROTECTION LAW (LGPD);
    • YOU HAVE BEEN INFORMED OF YOUR RIGHTS AS A DATA SUBJECT, INCLUDING ACCESS, CORRECTION, DELETION AND OTHER RIGHTS PROVIDED FOR IN THE LGPD;
    • RECEIVED CLEAR INFORMATION ABOUT THE PURPOSES FOR WHICH THEIR DATA WILL BE PROCESSED, THE DATA THAT WILL BE COLLECTED AND THE SECURITY MEASURES ADOPTED TO PROTECT IT;
    • UNDERSTANDS THAT PERSONAL DATA AND RESOURCES WILL BE PROCESSED IN ACCORDANCE WITH THE RULES ESTABLISHED BY SPA/MF ORDINANCE NO. 1.857/2024 AND CURRENT LEGISLATION, OBSERVING THE PRINCIPLE OF TRANSPARENCY.
    • YOU HAVE READ, ACCEPT AND AGREE TO BRAZINO777'S POLICIES, WHICH ARE: TERMS AND CONDITIONS, PRIVACY POLICY, RESPONSIBLE GAMING POLICY, INTEGRITY POLICY AND PREVENTION MANIPULATION OF RESULTS AND OTHER FRAUD, ANTI-MONEY LAUNDERING POLICY.

    The system will automatically record the date, time and IP address of your device at the time of acceptance, guaranteeing transparency and traceability.

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