1. PURPOSE OF THIS POLICY

1.1 This document describes the information collection and disclosure practices of the Web Site, owned by Intercomm International Business Corporation Srl (Registration No. 3-102-669911 to the Game Regulatory Authority of Costa Rica),
and Willis Casino (individually and collectively referred to as “the Operator”).

1.2 Your use of the Website and any content or applications available on it will be called the “Services”.

2. USE OF YOUR INFORMATION

2.1 Your personal information (ie, information about you by which you may be personally identified, such as name, address, phone number or email address, known in this Privacy Policy as “Your Information”), will be processed by
the Operator (including their agents and employees), and (as appropriate) by our partners and subcontractors in order to provide a wide range of services. Your information will be collected when you register to open an account with us,
or when you send us a written inquiry.

2.2 While the Web sites may contain links to other Web sites operated by third parties, the Operator is not responsible for the practices relating to the privacy or content of any such websites.

2.3 By using any of the Services, you agree that you have read and agree with the terms of this Privacy Policy and, by providing your information (including, for the avoidance of doubt, your a query through one of the web sites, or if
you have completed the registration process of your account only partially), you consent to the use of such information by the Operator (and our partners and subcontractors) for the purposes set out in paragraph 3 of this Privacy Policy.

2.4 If you do not wish to provide your information under the provisions of this Privacy Policy, you should not enter the relevant information in the spaces provided for such purpose in the corresponding section in any of the Websites,
or provide any personal information over the phone. However, unless you provide such information, you may not be allowed to use in full the relevant part of the Services.

2.5 As part of the registration process for your account, we also offer visitors registering with us the opportunity to choose not to be kept informed about future events, offers and promotions from the Operator. Visitors who wish to
opt for this option must “uncheck” the appropriate box on the registration process. You can update your marketing preferences at any time under “My Account / Update Marketing Preferences” (or similar) on the Web Site
(if that option is available) or by contacting the Customer Service. If, when the option is available, you have opted to receive information about upcoming events, offers and promotions by text messages to mobile phones, you will have
the option to stop receiving such information at any time by replying with the word “STOP “.

3. TYPE OF INFORMATION COLLECTED AND USE

3.1 The Operator will collect your information in order to:

3.1.1 Be able to open Your Account for you to use all the features of our Services, including, among others, add fund to your account, place bets and play games;

3.1.2 Receive your questions and comments through our Online Support Center, and answer them;

3.1.3 Comply with all applicable regulations regarding Your registration, for example, verification of age; and

3.1.4 (Provided you do not choose to be excluded from this option), keep you informed about future events, offers and promotions from the Operator.

3.2 In addition to a broad object identified in paragraph 3.1 above, the Operator will only use Your Information, including sharing Your Information with our partners and subcontractors who process data (including, where appropriate,
Your Information) on our behalf, to:

3.2.1 open, operate and manage Your Account;

3.2.2 provide all the services that you request and for any other purpose related to the provision of such services;

3.2.3 verify the accuracy of your information, including the disclosure of such information to third parties, including financial institutions and age verification agencies and credit reports, to that purpose. We will keep a record of
the verification and such third parties may use the information to assist other companies for verification purposes);

3.2.4 compile statistics regarding use of the Services by you and other customers;

3.2.5 develop and display material and appropriate individualized marketing content;

3.2.6 periodically send to account holders written communications to announce important service changes, updates on technical issues and changes to the Terms of Use (including this Privacy Policy);

3.2.7 fulfill our duties, obligations and regulatory responsibilities under the Gambling Act 2001, before the Regulatory Authority of Curacao, and in accordance with applicable law and with appropriate regulatory agencies in other
jurisdictions where the Operator develops a regulated activity;

3.2.8 meet legal requirements, or to take measures to protect the interests of sporting bodies or other relevant agencies;

3.2.9 investigate the suspected unlawful, fraudulent or inappropriate activities in relation to the Services;

3.2.10 report a criminal offense or suspicion, including money laundering or fraud of any kind, and

3.2.11 all other purposes necessary to fulfill our contractual obligations to you.

3.3 The Operator will not send you unsolicited information regarding commercial offers or third party publicity.

3.4 The Operator may use Your username and / or first name and region for advertising or promotional purposes.

3.5 Phone calls made or received by our Customer Service Department may be recorded for training and security purposes.

3.6 We may transfer Your information in case of transfer or sale of our business or part of it, including in the event of insolvency.

3.7 If at any time you wish to cease our activity processing your information for the purposes listed above, please contact us and we will take the appropriate steps to comply with your request. You should be aware that the decision
may involve the closure of Your Account.

4. INFORMATION TRANSFER ABROAD

4.1 Within the context of the provision of services, the Operator may need to transfer information (including, Your Information) to:

4.1.1 other companies within the same group of companies as the Operator, and

4.1.2 our partners and subcontractors located in their home countries

5. INFORMATION UPDATE

5.1 You may update or delete your information at any time from your account using the “My Account / Update my account” option (if available), or by contacting the Customer Service Department.

5.2 You may obtain a copy of Your information held by the Operator by contacting the Customer Service. We require to be notified in advance of up to THIRTY (30) days to fulfill your request.

6. CONTACT

6.1 If at any time you feel that the Operator has not complied with the principles contained in this Privacy Policy, you can contact the Customer Service, and we will use all commercially reasonable efforts to determine and correct
the problem as soon as possible.

7. PERIODS OF CONSERVATION OF PERSONAL DATA.

7.1 During the period in which personal data will be held by Intercomm International.Busines.Corporation Srl, the latter undertakes to ensure that such information is protected in an appropriate manner and that it is used
solely for the purposes set out in this statement.

7.2 The data will be kept for the entire period in which the user will entertain his business relationship with the Intercomm Int.Bus.Corporation. Srl

7.3 If the user ceases to maintain business relations with Intercomm Int.Bus.Corporation. Srl., Your personal data will be kept for the minimum period of time strictly necessary in order to respect the purposes
described in this Notice, and in compliance with current regulatory obligations. Normally this period of time does not exceed 10 years beyond the duration of the gaming account, except in some specific circumstances in which
it could be longer.

7.4 Personal data processed solely for commercial marketing purposes are not normally stored for more than 24 months beyond the duration of the account, but may be stored for longer in certain specifications
circumstances.

7.5 The conditions that may lead to the extension of the retention period of personal data may be, by way of non-limiting example:

the need to identify a user in case he registers again on the group sites, prevention and detection of criminal activities, preparation and defense of the rights and interests of the corporate group
in case of legal actions.

7.6 Outside the above cases, however, we inform you that personal data may remain stored in our systems for a longer period of time than is necessary, if this is caused by technical problems.

7.7 Effective Date of this Privacy Policy: June 30, 2018.

8. DIRECTIVES

(i) European Directives n. 2016/679 of 27 April 2016 entered into force on 25/05/2018, concerning the protection of individuals with regard to the processing of personal data.

Rights conferred by the REGULATION GDPR

8.1 In accordance with the European Regulation on the protection of privacy n. 2016/679 (General Data Protection Regulation – GDPR), entered into force on May 25, 2018, you have a series of rights on your personal data, which are
detailed below:

Right of access to personal data (Article 15 Reg. GDPR): You have the right to request a copy of the personal information that we keep about you. Please visit the Contact Us page to get in touch if
you want to make this request. In your contact, please provide as much information as possible to identify yourself, to help us collect information.
Right to cancel (Article 17 Reg. GDPR): you can ask us to delete your personal data where there are no legal bases that require us to continue processing this personal data. This right yes applies only under certain circumstances,
since legal obligations include periods of data retention.
Right to rectification of personal data (Article 16 Reg. GDPR): you can request that all personal data that we are processing be corrected.
Right to be informed: you have the right to be informed of any changes or use of your data.
Right to data portability (Article 20 Reg. GDPR): similarly to the right to access personal data, this right allows you to obtain your personal data in an electronic format that allows you to transfer such data to another
organization, if this is relevant.
Right to restrict / oppose the processing of personal data (Articles 18 and 21 Reg. GDPR): under certain circumstances, you have the right to oppose or restrict the processing of personal data of the user, where processing be
based on consent or our legitimate interest. However, despite the objections or the desire to limit processing, where there are valid legitimate reasons or legal obligations, we would be obliged to continue processing.
Rights related to decision making and automated profiling: the user has the right not to be subject to a decision based solely on automated processing, ie without human involvement, where this decision has a legal impact or
otherwise significantly affects you. We confirm that we do not make automated decisions of this kind;
Right to revoke the consent previously given (Article 7, paragraph 3, Reg. GDPR): the user will always have the right to proceed with the revocation of the consent previously given without prejudice to the lawfulness of the
treatment, even if this can not affect the data processing operations carried out when we had the consent;
Right to lodge a complaint (Article 51 of the GDPR Reg.): The user has the right to lodge a complaint with the competent authority for the protection of personal data.

8.2 At any time the user has the possibility to change the consent to the use of their personal data taking into consideration the points mentioned above.

(ii) European Guidelines 2002/58 on privacy and electronic communications, and any applicable local rule for this purpose in relation to electronic marketing in the European Union.

(iii) CAN-SPAM Act of 2003 (Public Law 108-187) of the United States in relation to electronic marketing in the United States.

(iv) Organic Law on Data Protection 15/1999 applicable in Spain.