PLAYER PRIVACY POLICY

Last updated: 26 February 2026

This player`s privacy policy (the “Policy”) applies to personal data that we, Triathlon Limited, hold about our users. In this Policy, “we,” “us,” and “our” means Triathlon Limited, a company registered in Cayman Islands and located at Maples Corporate Services Limited, PO Box 309, Ugland House, Grand Cayman, KY1-1104, Cayman Islands, with commercial register number 380697 (“we”, “our”, “us” or “Triathlon Limited ”). This Policy deals with where we are acting as a 'data controller' under the data protection legislation: which essentially means where we are responsible for deciding what personal data we collect and how we use it. We may also operate as a 'data processor', meaning that we are processing personal data on behalf of another entity (for example, a publisher of one of our Games). When we refer to "Personal Data”, we mean “personal” relating to you personally or from which you can be identified. Some of the information mentioned in this Policy is not "Personal Data" as is meant under data protection legislation, but we may refer to it to help you understand what we do.

We are committed to protecting and respecting the personal data of everyone we deal with - that is important to us and we know it is important to you.

In this Policy, “you” or “your” means the individual User with a licence to access or use the Digital Goods, Games, Virtual Items, Virtual Currency, Triathlon Limited ’s’ Websites, stores, any other digital online properties or services, marketing services, live events, and other activities that link to this Privacy Policy and other related services made available from time to time. If the user is younger than 18 years of age (or the minimum legal age of adults in your territory), then "you" or "your" shall mean the user's parent or legal guardian entering into a legally binding contract with us on behalf of your minor child. If you are younger than 18 years of age (or the minimum legal age of adults in your territory), you must review this Policy with your parent(s) or legal guardian(s), and they must agree to these terms on your behalf and take full responsibility for your compliance with them. A summary of this Policy, specifically written for young people, is available here.

If you accept this Policy on behalf of your minor child, you are responsible for supervising and monitoring your minor child in using the licence for any Digital Goods & Services made available from time to time by us. You are also legally and financially responsible for all of your minor child's actions while using the licence to and accessing our Digital Goods & Services.

In this Policy, you will also find information about what types of personal data we hold about you, how and why we collect it, how we use it, and how we keep it secure. You will also find information about your rights and how you may exercise them. This Policy is drafted in the English language and will be translated into other languages. The English language version of this Policy shall prevail if there is any conflict or inconsistency that requires clarification. All capitalised words in this Policy shall have the same meaning as in the Terms of Use.

Please read this Policy carefully, and if you need to contact us about anything that is in here, or for anything else related to your personal data, you can reach us by email at johnsontriathlon636@gmail.com or by post at the address above.

You'll find in this policy information about the following:

What information do we collect about you?

We will collect some information about you. The type of personal data that we collect about you depends on how you access and use our Digital Goods & Services. In general, we collect the following information:

A. Personal data that you provide directly to us:

1. Your contact information, such as name, email address and if you choose to provide your phone number and date of birth;
2. If you are a parent or legal guardian of a minor child, we will collect your email address;
3. Your in-game User ID;
4. Data that you provided to us to verify your Account;
5. Other data you choose to provide us, such as data to identify a lost or lapsed account or the answer to a special question we may ask you in order to permit you to unlock or recover a lost or lapsed account;
6. Information about your purchase and payment (in addition, exclusively our payment service providers will collect your payment details in connection with any purchases you make through our webstore);
7. Personal data you provide in connection with surveys, promotions, sweepstakes, competitions, campaigns and other events;
8. Personal data that may be collected for the purpose of verifying your legal relationship with your parent(s) or legal guardian(s); and
9. Other Personal data that may be collected based on your explicit consent or our legitimate business interest for a specific purpose.

B. Personal data that we collect automatically when you access and use our Digital Goods & Services:

1. Your Game profile, including your profile picture and any information needed for the game to function, such as an inventory of in-game items;
2. Your Game User Account or role ID(s) – generated by our game server for you;
3. Analytics ID – a randomly generated anonymous identifier used to distinguish activity from one Game account versus another in our analytics data;
4. Your internet protocol (IP) address and mobile device identifiers (such as for example your device ID, advertising ID, MAC address, IMEI);
5. Data to fight fraud (such as refund abuse in Games or click fraud in advertising);
6. Usage data, including information about how you use our website, products, and services, and your Game progress;
7. Data about your device, such as device name and operating system, browser type, and language; and
8. Marketing and communications data,  including your preferences in receiving marketing from us and our third parties and your communication preferences, and it is at your full own discretion and control to adjust the settings on your device to turn off the function.

C. Personal data that we collect from third parties:

1. Third-party account ID – for example, your Account with Facebook, Xbox, Game Center, VK, WeChat, Google, Steam or PSN, which you may use to sign into your Game Account, leverage your social graph, or integrate with third-party features (such as achievements);
2. Feedback and suggestions you post on third-party platforms that relate to improving the Game experience with our services.
3. Payment confirmation details, including the purchases you make and the amount you spend; and
4. We collect social media account information (such as Instagram, X, YouTube, TikTok, Discord, Kakao, or WeChat) either directly from you when you provide it (e.g., by linking an account), or from third-party services where you have made such information publicly available or consented to its sharing.

How we collect information about you

We will collect this information in a variety of ways, depending on how we interact with you.

How we use your information

We use different information for various purposes, such as:

• • • To send you communications related to our Digital Goods & Services, answer your enquiries or deal with your complaints;
    • If you are a parent or legal guardian of a minor child, we will use your personal data to communicate with you to obtain your consent on behalf of your minor child;
    • Providing, managing, and customising our services, including our Games;
    • Customising your personal Game experience;
    • Allowing you to participate in our website features;
    • Enable you to purchase virtual items and complete the related payment transactions;
    • Verifying and confirming payments on the game top-up centre (where relevant interacting with third-party payment providers);
    • Account verification and clearance;
    • Website administration and system administration;
    • Marketing and advertising to inform you about products and services that may be of particular interest to you;
    • Administering surveys and opinion polls;
    • Managing competitions and/or promotions and your registration for the same;
    • On-site and in-app advertising and promotion of our Digital Goods & Servicesand those of our service providers and trusted third parties;
    • Technical and usage information/analytics to help us develop Games that our customers want to play and to improve them, and to detect cheating and activities that ruin the experience of Users playing our Games, security risks, fraud and other unlawful activity;
    • The provision of social features as part of our services;
    • To send you related information such as updates, security alerts and support messages;
    • Leaderboards, Discord and community information, nicknames and club name/club information;
    • To moderate User-Generated Content (UGC) that you submit in our Game and communications between players, either automatically or manually;
    • To answer or satisfy legal or regulatory requirements; and
    • When you interact with third-party social networking features to serve you with advertisements and engage with you on third-party social networks (we encourage you to review the privacy notices/policies of these social networks to enable you to opt out of such activities).

Cookies

Like most online services, we and our partners may use cookies and similar technologies to provide and personalise our services, analyse gaming usage, target advertisements, and prevent fraud. Cookies are small text files stored by browsers on your desktop computer or mobile device. To clarify, a cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can modify the browser settings to decline cookies if you wish so. In that case, some aspects of the service may then not function properly.

We and our partners may use tracking technologies such as cookies, beacons, tags and scripts. These technologies are used in analysing trends, administering the websites, tracking users’ movements around the websites, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as an aggregated basis.

Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our websites, but your ability to use some features or areas of our websites may be limited.

Legal basis for processing

There are a number of different legal grounds for processing personal data. Which one is applicable will depend on how we are using your information and for what purpose. In the majority of cases, this condition will be that:

• • • You have provided your consent to us using your personal data in that way (for example, where you provide us with consent to send you marketing communications about our products and services); and/or
    • Our use of your personal data is in our legitimate interest as a commercial organisation, provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights; and/or
    • Our use of your personal data is necessary to perform a contract or take steps to enter into a contract with you (e.g. to manage your Account); and/or
    • Our use of your personal data is necessary to comply with a relevant legal or regulatory obligation.

We generally do not collect or process any 'special categories' of personal data (including information regarding your health, religious or political beliefs, ethnic background, sexual life, and sexual orientation). If this applies, we will generally rely on obtaining additional specific consent from you at the time we collect the information unless there is a legal requirement or other justification for processing that information.

Children

Protecting children’s privacy is of high importance to us. Our Digital Goods & Services are not intended for children younger than 18 years of age (or the minimum legal age of adults in your territory), and we do not knowingly collect data relating to children under 13 years old in the United States and 16 years old in some EU Jurisdictions. In respect of Games that are not directed at children but which may nonetheless appeal to them, we take additional steps to limit access to our services based on the User’s age.

When you access our Digital Goods & Services, we may restrict the collection of personal data of a minor child. We will ask the parent's permission before collecting the minor child's personal information. If we become aware that a minor child has provided personal information without a parent's permission, we will promptly delete this information or suspend the Account until we obtain the parent's consent.

A parent may withdraw consent, review, access, or change their minor child’s personal data. Please go to section 10 below to see how you can exercise your rights.

Sharing your information

• 1. We may share your Personal Data with Triathlon Limited ’s group affiliates that are located outside your country of residence. On a need-to-know and data minimisation basis only, specific staff in certain entities are granted restricted and secure remote access solely to perform specific services and functions as outlined in Section 3 above. Such access is strictly limited to authorised personnel or departments, and is governed by robust security measures and formal authorisation protocols.
  2. The Personal Data you provide to us may be shared with third-party companies, agents, contractors, service providers, or our affiliated companies if this is necessary to provide you with our services, respond to your inquiries, or for any of the purposes described in this Policy. This may include:
     • • Our business and development partners and suppliers;
       • Payment service providers. For payment purposes on our webstore, our payment service providers will collect your payment details in connection with any purchases you make through the game’s webstore. For more information on how the payment service providers process your personal data, please read their privacy policies;
       • Third-party service providers who store or process the information on our behalf, in particular data analytics providers and data storage providers. Information shared with such providers is supplied in an anonymised format, such data cannot be linked to any particular individual and is therefore not considered to be 'personal data;
       • Advertising Partners. Third-party advertising companies for interest-based advertising purposes
       • Our auditors, insurers, lawyers, and other professional advisers;
       • Law enforcement agencies, other governmental agencies or third parties if we are required by law to do so;
       • Other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.
  3. Public sharing

When you share your personal data, post an image or video, or provide other UGC in public platforms or forums, other people can view, collect and use that information.

Other Users may also see your Game profile, which contains your profile picture and nickname. If you use your real name as your nickname, that information will be publicly available on your Game profile and leaderboards or elsewhere as described in this Privacy Policy.

Users in a public platform or forum may use such information to identify you or use the information to send you messages. We cannot guarantee privacy or confidentiality on any of the public platforms or forums. Therefore, we strongly recommend that you not share your personal data in public forums or use your real name in your nickname. You are solely responsible for any information, content, or UGC you publicly post when accessing our Digital Goods & Services.

Social Features

Social features are a core component of our Digital Goods & Services. Other Users may, for example, see your profile data, in-game activities, and read the messages you have posted.

Our Digital Goods & Services may include features from our partners, if any, such as social media interaction tools (and albeit not currently, in the future may also relate to in-game advertising). These partners, if any, may in such case, following your consent, access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices and opt out where you deem relevant.

International Data Transfers

We may process and transfer your Personal Data to countries outside the jurisdiction in which you reside where our group companies or service providers are located.

When transferring Personal Data to another country, we comply with the requirements of applicable law, including obligations to ensure that the transferred Personal Data is performed with an appropriate or comparable level of protection, or that other lawful grounds for such transfer exist.

We may transfer Personal Data internationally where appropriate safeguards are in place, including through contractual arrangements, binding corporate rules, or other legally enforceable mechanisms, as required or permitted by applicable law.

In addition, Personal Data may be transferred to another country where one or more of the following circumstances apply:

• the data subject has provided consent to the transfer, where required;
• the transfer is necessary for the performance of a contract with the data subject or for the implementation of pre-contractual measures at the data subject’s request;
• the transfer is required or authorised by law or necessary to protect legally protected interests of the data subject; or
• the transfer is otherwise permitted under applicable law.

We take reasonable administrative, technical, and organisational measures to protect Personal Data transferred across borders against unauthorised access, use, disclosure, alteration, or loss.

For further information about our international data transfers, you may contact the Privacy Office at johnsontriathlon636@gmail.com.

Your rights

Under the data protection laws, you have a number of rights in relation to your personal data. We respect and honour these rights and will help you to exercise them insofar as we are able. Depending on your location, you may have certain rights over your personal information, including the right to:

• • • To request access to or a copy of any personal data which we hold about you;
    • To rectify your personal data, if you consider that the information we are holding is inaccurate;
    • To ask us to delete your personal data, if you consider that we do not have the right to hold it;
    • To withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
    • To ask us to stop or start sending you marketing messages as described below in the marketing section;
    • To restrict the processing of your personal data;
    • To data portability (moving some of your personal data elsewhere) in certain circumstances;
    • To object to your personal data being processed in certain circumstances; and
    • To not be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.

Please note that these rights are not absolute – in some cases they will not apply to you, or to the particular use that we are making of your data, and there are exceptions (for example if we have to process the data to comply with our own legal obligations) but if that is the case we will let you know if you make a request that we believe we cannot comply with.

You can exercise and submit these rights bysending your request in writing to our Privacy Office privacyoffice@lightningpiggy.com; or undertaking self-account deletion directly in the Game; or contacting our Triathlon Limited Support Team via the in-game app if you want to delete your Account and personal data.

We may take steps to verify your identity before we can respond to your request. We will also endeavour to respond within a reasonable period and in any event within one month in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a data subject.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up-to-date, you have the option to fully control the data you share with us, and you may update your information directly under your profile or adjust the settings on your device.

Inquiries not related to data protection matters, such as requests, questions, complaints or feedback relating to our Digital Goods & Services, will not be answered by the Privacy Office. The Privacy Office will forward such requests, questions, and complaints to the Triathlon Limited Support Team, which will respond to these inquiries.

Marketing

If you have accepted to receive notifications for a certain game, we may use your personal data to send you tailored suggestions, offers, or auction information about the Game. For personalised in-game offers opt-out, you can use the options provided in the Game settings. You can easily turn off the notifications in each different category within the Game or opt-out from receiving notifications or alerts on your device.

You can opt-out of interest-based advertising on mobile applications, if any, by checking the privacy settings of your Android or iOS device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest-based ads" (Android).

How long will we keep your information?

We will only keep the information we collect about you for as long as required for the purposes set out in this notice or as required to comply with any legal obligations to which we are subject. This will involve us periodically reviewing our files to check that information is accurate, up-to-date, and still required. When you are still active playing our Games, we will retain your personal data to administer and provide you access to the Digital Goods & Services.

By law we have to keep basic information about our customers (including contact, identity data, (and financial and transaction data relating to transactions via our store, if any)) for six tax years plus the current tax year after they cease being customers for tax purposes.

In some circumstances, you can ask us to delete your data: see "Your rights" for further information.

If your Account has been inactive for 365 consecutive days, we may delete, de-identify, or anonymise your Account, and you may no longer be able to access your Account. However, we may still retain some of your personal data in our files for a reasonable period of time to resolve disputes, enforce our Terms and Privacy Policy, and comply with technical and legal requirements and other security-related requirements.

We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

If you opt-out from marketing, we may retain the necessary information to enable us to respect your wishes to not be contacted for marketing purposes.

Data Security

We have implemented appropriate technical and organisational measures (“TOMs”) to protect your personal data against unauthorised access or disclosure, unintentional changes or loss, and unlawful and unauthorised processing activities. We also have implemented procedures and technologies to maintain the security of all personal data that we process during its lifecycle (from the point of collection to the point of destruction) by maintaining the confidentiality, integrity and availability of the personal data.

Such measures will be appropriate to the nature of the data concerned and the level of risk. If you have been provided with a password to access any of our services, you should not share that password with anyone else.

However, no security measures are perfect and can be 100% secure. We cannot guarantee our security measures, but we will do our best to protect your personal data in accordance with the applicable data protection laws and international security standards.

Links to Other Sites

Our websites may contain links to other sites, including via our social media buttons. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites and a link does not constitute an endorsement of that website. Once you link to another website from our website, you are subject to the terms and conditions of that website, including, but not limited to, the relevant website’s privacy policy and practices. Please check these policies before you submit any data to these websites.

Contact

Questions, comments, and requests regarding this Policy are welcomed and should be addressed to Triathlon Limited, a company registered in Cayman Islands and located at Maples Corporate Services Limited, PO Box 309, Ugland House, Grand Cayman, KY1-1104, Cayman Islands or by email to johnsontriathlon636@gmail.com.

Changes to this policy

Any changes we make to our Policy in the future will be posted on this page and, where material and appropriate, notified to you by in-game message. We urge you to check regularly to see any updates or changes to our Policy.

By accepting the new Policy or by continuing to use the Digital Goods & Services after the update of this Policy becomes effective, you agree to be bound by the updated Policy. If you do not wish to agree to the updated Privacy Policy, you may terminate your use of the Digital Goods & Services.

© 2026 Triathlon Limited . All Rights Reserved.