Privacy Notice

Axi Technologies US LLC – OddsOn Platform

1. Who We Are

Axi Technologies US LLC ("we", "us", "our") is a limited liability company registered in the State of Wyoming, United States. We operate the OddsOn prediction trading platform (the "Platform"), including the challenge programme and funded trader experience.

This Privacy Notice explains how we collect, use, disclose, and protect personal data when you access or use the Platform, register an account, participate in a challenge, or otherwise interact with us. It also explains your rights in relation to your personal data.

The Platform is available in most US states. However, the following geographic restrictions apply in accordance with applicable law:

• Arizona – the Platform is not available to Arizona residents for any event contracts (sports or non-sports).
• Illinois, Maryland, Massachusetts, Michigan, Nevada, New Jersey, and Ohio – the Platform is not available to residents of these states for sports event contracts.

For questions about this Notice or our data practices, please contact our Privacy Officer at privacy@oddson.co or by post at 30 N Gould Street, #64730, Sheridan, Wyoming 82801.

2. Regulatory and Legal Framework

Axi Technologies US LLC collects, uses, discloses, and retains personal data in accordance with applicable US federal and state law, including:

• the California Consumer Privacy Act 2018, as amended by the California Privacy Rights Act (together, CCPA/CPRA);
• applicable US state consumer privacy laws, including those of Colorado, Connecticut, Virginia, Texas, Florida, Oregon, and Montana;
• the Gramm-Leach-Bliley Act (GLBA) – a US federal law that requires financial institutions to explain how they share and protect their customers' non-public personal information, and to give customers certain opt-out rights;
• the Bank Secrecy Act (BSA) – a US federal law that requires financial institutions to assist government agencies in detecting and preventing money laundering, including by maintaining records of customer transactions and identities;
• anti-money laundering (AML), sanctions screening, and know-your-customer (KYC) obligations;
• rules and regulations of the Commodity Futures Trading Commission (CFTC) – the US federal regulator for derivatives markets including futures and certain prediction markets;
• compliance requirements of the National Futures Association (NFA) – the self-regulatory organisation for the US derivatives industry; and
• applicable electronic marketing and communications laws.

Where required by law or regulation, certain personal data and transaction records may be retained for extended periods, including after account closure.

3. Personal Data We Collect

We collect the following categories of personal data:

3.1 Identity and Contact Data

• Full name
• Date of birth
• Residential address
• Email address
• Phone number

3.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g. passport, driver's licence)
• Proof of address documentation
• Selfie or liveness check image (where required for identity verification)
• Tax identification number (including for US 1099 reporting purposes where applicable)
• Face geometry scan derived from liveness check or photo ID (biometric data – see Section 11)

3.3 Financial and Account Data

• Challenge entry fee payment records
• Payout requests and payment method details (e.g. bank account, crypto wallet address)
• Challenge tier selected and entry history
• Funded account status and profit share entitlements

3.4 Trading and Platform Activity Data

• Trade history, market selections, and call placements
• Challenge progress, drawdown levels, and performance metrics
• Login timestamps, session data, and device identifiers
• IP address and approximate geolocation
• In-app behaviour and feature usage

3.5 Compliance and Surveillance Data

• Account linkage and duplicate account detection data
• Suspicious trading pattern flags
• Fraud indicators and risk scores
• Communications with our support team

3.6 Marketing and Communications Data

• Marketing preferences and opt-in/opt-out status
• Email engagement data (opens, clicks)
• Referral source and acquisition channel
• Discord, chat, or community interactions where applicable

4. How We Collect Your Personal Data

We collect personal data:

• Directly from you, when you register an account, complete identity verification, enter a challenge, request a payout, or contact our support team;
• Automatically, through your use of the Platform, including via cookies, analytics tools, and our trading infrastructure;
• From third parties, including identity verification providers, KYC/AML screening services, payment processors, and our market infrastructure partner; and
• From publicly available sources, where relevant to compliance or fraud prevention purposes.

5. How We Use Your Personal Data

5.1 To operate and administer the Platform

We use your personal data to create and manage your account, process challenge entries, record your trading activity, calculate challenge outcomes, and administer funded account and payout arrangements. This processing is necessary to perform our contract with you.

5.2 To comply with legal and regulatory obligations

We are required to collect, verify, and retain certain personal data – including KYC documentation, trading records, and tax information – to comply with applicable US federal and state law, CFTC and NFA rules, BSA record-keeping requirements, and AML obligations. This processing is necessary for compliance with a legal obligation.

5.3 To comply with GLBA financial privacy obligations

As an entity operating within a regulated financial market environment, we are subject to the Gramm-Leach-Bliley Act. We collect and share certain non-public personal financial information as required to operate the Platform, subject to the opt-out rights described in Section 10 and our GLBA Consumer Privacy Notice in Section 12.

5.4 To detect and prevent fraud, abuse, and market manipulation

We monitor trading behaviour, account activity, and platform usage to detect duplicate accounts, collusion, payout abuse, rule breaches, and other forms of fraud or market manipulation. This processing is in our legitimate interests to maintain the integrity of the Platform.

5.5 To process payouts and handle disputes

We use your identity, payment, and trading data to verify payout eligibility, process payment, issue tax documentation where required, and handle any payout disputes. This processing is necessary to perform our contract with you and to comply with applicable law.

5.6 To provide customer support

We use your account and trading data to respond to support queries, resolve settlement disputes, and handle challenge rule queries. This processing is necessary to perform our contract with you.

5.7 To send you service and operational communications

We will contact you with information about your account, challenge progress, settlement outcomes, payout status, and material changes to the Platform or these terms. This processing is necessary to perform our contract with you.

5.8 To send you marketing communications

Where you have opted in, we may send you promotional communications about new challenge tiers, offers, and Platform features. You may withdraw your consent at any time by clicking 'unsubscribe' in any marketing email or by contacting us at privacy@oddson.co. We will not send you unsolicited marketing.

5.9 To use AI tools in our operations

We may process your personal data using internal and third-party AI tools to improve the efficiency and quality of our operations, including for sanctions screening during KYC onboarding. We do not use AI tools for automated decision-making that produces legal or similarly significant effects on you without human review.

5.10 To analyse and improve the Platform

We use aggregated and pseudonymised platform data to understand user behaviour, measure challenge completion rates, and improve our product. This processing is in our legitimate interests.

6. Who We Share Your Personal Data With

We share your personal data with the following categories of recipients:

• our market infrastructure and exchange services partner, who processes trading data, compliance data, and KYC data necessary to operate the Platform.
• Identity verification and KYC providers – third-party services used to verify your identity and screen against AML and sanctions lists.
• Payment processors – to facilitate challenge entry fee payments and trader payouts.
• Analytics and technology service providers – including analytics platforms, cloud hosting, and CRM providers, who process data on our behalf under appropriate data processing agreements.
• Legal, regulatory, and law enforcement authorities – where we are required to disclose information by law, court order, or regulatory request, including to the CFTC, NFA, or other applicable regulators.
• Professional advisers – including lawyers, accountants, and auditors, subject to confidentiality obligations.
• Third parties in connection with a sale, merger, or restructuring of our business, where your data is transferred as part of that transaction.

We do not sell your personal data to non-affiliated third parties for their own marketing purposes.

7. International Data Transfers

Axi Technologies US LLC is based in the United States. If you access the Platform from outside the US, your personal data will be transferred to and processed in the United States. We will ensure that any such transfer is subject to appropriate safeguards in accordance with applicable data protection law.

Our service providers and market partners may also process data in jurisdictions outside your country of residence. Where this is the case, we take steps to ensure adequate protections are in place.

8. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes described in this Notice, including:

• Account and identity data – for the duration of your account and for a minimum of five years following account closure, to comply with AML and regulatory record-keeping obligations.
• Trading and challenge data – for a minimum of five years from the date of the relevant transaction, in accordance with applicable CFTC and NFA requirements.
• KYC documentation – for the period required under applicable AML law and BSA obligations, typically five years from the end of the customer relationship.
• Biometric data (face scan) – until the purpose for which it was collected has been satisfied, or three years from your last interaction with us, whichever is earlier, unless otherwise required by law. See Section 11.
• Tax documentation – for the period required under applicable US federal and state tax law.
• Marketing data – until you withdraw consent or opt out.

Where retention is no longer required, we will securely delete or anonymise your personal data.

9. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include access controls, encryption, intrusion detection systems, and security monitoring.

No method of transmission over the internet is completely secure. If you become aware of any security concern relating to your account, please contact us immediately at support@oddson.co.

10. Your US Privacy Rights

Depending on your state of residence and applicable law, you may have the following rights in relation to your personal data:

• Right to know – to know what categories of personal data we collect about you, the sources of that data, the purposes for which we use it, and the categories of third parties with whom we share it.
• Right of access – to obtain a copy of the personal data we hold about you.
• Right to correction – to request that inaccurate or incomplete data be corrected.
• Right to deletion – to request deletion of your personal data, subject to our legal and regulatory retention obligations.
• Right to opt out of sale or sharing – to opt out of the sale or sharing of your personal data for targeted advertising purposes. We do not sell personal data as defined under the CCPA.
• Right to limit use of sensitive personal data – where applicable under state law, to limit our use of sensitive personal data (including biometric data) to purposes necessary to provide the Platform.
• Right to non-discrimination – you will not receive discriminatory treatment for exercising any of the rights described in this Notice.

California residents have additional rights under the CCPA/CPRA, including the right to know about personal data sold or shared in the preceding 12 months and the right to designate an authorised agent to make requests on your behalf.

Vermont residents: we will not disclose information about your creditworthiness to our affiliates, and will not disclose your personal data to non-affiliated third parties for marketing purposes except as permitted by Vermont law.

To exercise any of your rights, please contact our Privacy Officer at privacy@oddson.co. We will respond within the timeframe required by applicable law and may need to verify your identity before processing your request.

11. Biometric Data (Illinois BIPA Notice)

The Platform may collect biometric data as part of the KYC onboarding process. If so, this section applies to Illinois residents under the Illinois Biometric Information Privacy Act (BIPA).

Biometric data may include a scan of your face geometry derived from a selfie image or photo identification document you provide. Where we collect this data, we do so for the purpose of verifying your identity, complying with AML and KYC obligations, and preventing fraud.

We do not sell, lease, trade, or otherwise profit from your biometric data. We do not share biometric data with third parties except as required by law or to complete identity verification on our behalf.

Where biometric data is collected, we will retain it until the earlier of: (i) the purpose for which it was collected has been satisfied; or (ii) three years following your last interaction with us – unless a longer period is required by applicable law or court order.

If biometric data is collected as part of your onboarding, you will be asked to provide your explicit consent at that point before any biometric data is collected. You may withdraw consent by contacting us at privacy@oddson.co, but doing so may prevent us from providing the Platform to you.

Please note that Illinois residents are restricted from accessing sports event contracts on the Platform regardless of the above.

12. GLBA Consumer Privacy Notice

The Gramm-Leach-Bliley Act (GLBA) requires us to tell you how we collect, share, and protect your personal financial information. The following summarises our practices.

We collect personal financial information such as your name, address, date of birth, social security number or tax ID, account balances, and transaction history when you register for the Platform or use our services.

We share personal financial information:

• With service providers necessary to operate the Platform – you cannot limit this sharing as it is essential to the provision of our services;
• With regulators, law enforcement agencies, and courts where required by law – you cannot limit this sharing; and
• For our own marketing purposes – you may opt out at any time by contacting us at privacy@oddson.co.

We do not share personal financial information with non-affiliated third parties for their own marketing purposes.

We protect your personal financial information using physical, electronic, and procedural safeguards, including encryption, access controls, and secured systems.

13. USA PATRIOT Act Notice

To help the US government fight the funding of terrorism and money laundering activities, US federal law (the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act 2001) requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.

What this means for you: when you open an account on the Platform, we will ask for your name, address, date of birth, and other identifying information. We may also ask to see your government-issued photo identification or other identifying documents.

14. Cookies and Tracking Technologies

We use cookies and similar tracking technologies on the Platform to:

• Keep you logged in and maintain your session;
• Remember your preferences;
• Analyse Platform usage and performance; and
• Support fraud detection and security monitoring.

You can manage your cookie preferences through your browser settings or our Cookie Preferences centre available on the Platform. Note that disabling certain cookies may affect Platform functionality. Our Cookie Policy contains further detail.

15. Minors

The Platform is not directed at persons under the age of 18, or any higher minimum age required by applicable law. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected data from a minor, please contact us and we will take steps to delete it promptly.

16. Third-Party Services

Our website or Platform may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices, policies, or content of those third-party services and encourage you to read their privacy notices before providing any personal data.

17. Changes to This Notice

We may update this Privacy Notice from time to time. Where we make material changes, we will notify you by email or by prominent notice on the Platform prior to the change taking effect. The date at the top of this Notice indicates when it was last revised. Your continued use of the Platform after a change takes effect constitutes acceptance of the updated Notice.

18. Contact Us

If you have any questions about this Privacy Notice or our data practices, or wish to exercise your rights, please contact:

Privacy Officer, Axi Technologies US LLC

• Email: privacy@oddson.co
• Post: 30 N Gould Street, #64730, Sheridan, Wyoming 82801
• Security concerns: support@oddson.co

If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction. California residents may contact the California Privacy Protection Agency. Illinois residents may contact the Illinois Attorney General.