BALLDRAFT / HUNGER MADRA LLC PRIVACY POLICY

Marketing and Advertising Partners:

• Email marketing and communication platforms
• Social media advertising networks and demand-side platforms
• Affiliate marketing networks and promotional partners
• Market research and survey service providers

5.2 Legal and Regulatory Disclosures

We may disclose your personal information when required or permitted by law, including:

Government Authorities and Regulators:

• Gaming commissions and regulatory authorities overseeing daily fantasy sports
• Tax authorities requiring reporting of winnings and financial transactions
• Law enforcement agencies investigating criminal activity or regulatory violations
• Courts and legal tribunals in response to subpoenas, court orders, or legal process

Legal Proceedings and Investigations:

• Responding to lawful requests for information from government agencies
• Cooperating with investigations into fraudulent activity or Terms violations
• Defending against legal claims or protecting our legal rights and interests
• Complying with anti-money laundering reporting requirements

5.3 Business Transfers and Corporate Transactions

In the event of a merger, acquisition, consolidation, restructuring, sale of assets, bankruptcy, or other corporate transaction involving BallDraft / Hunger Madra LLC, your personal information may be transferred to the acquiring entity or successor organization, subject to appropriate confidentiality and data protection commitments.

5.4 Consent-Based Sharing

We may share your personal information with third parties when you have provided explicit consent for such sharing, including:

• Social media platforms when you choose to share contest results or achievements
• Third-party applications and services that you choose to integrate with your BallDraft / Hunger Madra LLC account
• Marketing partners for co-branded promotions or joint marketing initiatives
• Research organizations for industry studies and market analysis (in aggregated, anonymized form)

5.5 Aggregated and Anonymized Information

BallDraft / Hunger Madra LLC may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify individual users with third parties for various business purposes, including industry analysis, marketing research, and platform optimization. Such information does not constitute personal information under this Policy.

6. DATA RETENTION AND STORAGE

6.1 Retention Periods

BallDraft / Hunger Madra LLC retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Account Information: Retained for the duration of your active account plus seven (7) years following account closure for legal compliance and dispute resolution purposes.
• Financial Records: Retained for a minimum of ten (10) years following the last transaction to comply with financial regulations, tax requirements, and anti-money laundering laws.
• Contest and Gaming Data: Retained for five (5) years following contest completion for regulatory compliance, dispute resolution, and platform integrity purposes.
• Communication Records: Retained for three (3) years following the last communication for customer service quality assurance and legal protection.
• Identity Verification Documents: Retained for seven (7) years following account closure or as required by applicable know-your-customer and anti-money laundering regulations.

6.2 Secure Data Storage

All personal information collected by BallDraft / Hunger Madra LLC is stored on secure servers located within Nigeria or in jurisdictions with adequate data protection laws as recognized by Nigerian authorities. We implement industry-standard security measures including:

• Advanced encryption protocols for data transmission and storage
• Multi-factor authentication systems for administrative access
• Regular security audits and penetration testing
• Firewalls, intrusion detection systems, and network monitoring
• Secure backup procedures and disaster recovery protocols
• Employee access controls and security training programs

6.3 Data Deletion and Destruction

Upon expiration of applicable retention periods, BallDraft / Hunger Madra LLC will securely delete or destroy personal information using industry-standard data destruction methods to prevent unauthorized recovery or reconstruction of deleted information.

7. YOUR PRIVACY RIGHTS AND CHOICES

7.1 Access and Correction Rights

You have the right to access, review, and request correction of your personal information held by BallDraft / Hunger Madra LLC. To exercise these rights, you may:

• Access your account settings to view and update certain personal information
• Contact our customer service department to request access to additional information
• Submit written requests for correction of inaccurate or incomplete information
• Provide supporting documentation for requested corrections or updates

7.2 Data Portability and Deletion

Subject to legal and regulatory requirements, you may request:

• Data Portability: Receipt of your personal information in a structured, commonly used, and machine-readable format
• Data Deletion: Deletion of your personal information, except where retention is required by law or legitimate business interests
• Processing Restriction: Limitation of how we process your personal information in certain circumstances

7.3 Marketing Communications and Opt-Out Rights

You have the right to control how BallDraft / Hunger Madra LLC communicates with you regarding marketing and promotional materials:

• Email Marketing: Unsubscribe from marketing emails using the unsubscribe link or account settings
• SMS Marketing: Reply "STOP" to text messages or update preferences in your account
• Push Notifications: Disable push notifications through your device settings or app preferences
• Direct Mail: Request removal from physical mailing lists by contacting customer service

Please note that even if you opt out of marketing communications, we may still send you transactional, administrative, and service-related communications that are necessary for your use of the Platform.

7.4 Cookie Management and Tracking Preferences

You can control cookie settings and tracking preferences through:

• Browser settings to block, delete, or manage cookies
• Platform privacy settings to control data collection and personalization
• Third-party opt-out mechanisms for advertising and analytics cookies
• Do Not Track browser settings (where technically feasible)

8. INTERNATIONAL DATA TRANSFERS AND CROSS-BORDER PROCESSING

8.1 Transfer Mechanisms

In certain circumstances, BallDraft / Hunger Madra LLC may transfer your personal information to countries outside of Nigeria for processing by our service providers, business partners, or affiliated entities. All international transfers are conducted in accordance with applicable Nigerian data protection laws and international best practices.

8.2 Adequacy Determinations and Safeguards

When transferring personal information internationally, we ensure appropriate safeguards are in place, including:

• Transferring only to countries with adequate data protection laws as recognized by Nigerian authorities
• Implementing contractual data protection clauses with third-party recipients
• Requiring service providers to maintain equivalent levels of data protection
• Conducting due diligence assessments of international transfer recipients

8.3 Legal Basis for International Transfers

International transfers of your personal information are based on:

• Your explicit consent to such transfers
• Necessity for the performance of our contract with you
• Compliance with legal obligations under Nigerian or international law
• Protection of your vital interests or those of other individuals
• Legitimate interests pursued by BallDraft / Hunger Madra LLC, provided such interests are not overridden by your privacy rights

9. SECURITY MEASURES AND DATA PROTECTION

9.1 Comprehensive Security Framework

BallDraft / Hunger Madra LLC implements a comprehensive, multi-layered security framework designed to protect your personal information against unauthorized access, use, disclosure, alteration, or destruction. Our security measures include:

Technical Safeguards:

• End-to-end encryption for data transmission using industry-standard protocols (TLS 1.3 or higher)
• Advanced encryption algorithms (AES-256 or equivalent) for data storage and databases
• Secure socket layer (SSL) certificates for all web communications
• Multi-factor authentication requirements for administrative and user account access
• Intrusion detection and prevention systems with real-time monitoring
• Regular vulnerability assessments and penetration testing by certified security professionals
• Automated backup systems with encrypted off-site storage and disaster recovery capabilities

Administrative Safeguards:

• Comprehensive employee background checks and security clearance procedures
• Mandatory privacy and security training programs for all personnel with access to personal information
• Principle of least privilege access controls limiting employee access to necessary information only
• Regular security awareness training and phishing simulation exercises
• Incident response procedures and data breach notification protocols
• Third-party vendor security assessments and contractual data protection requirements

Physical Safeguards:

• Secure data centers with biometric access controls and 24/7 security monitoring
• Environmental controls including fire suppression, temperature regulation, and power redundancy
• Restricted access to server rooms and computing equipment
• Secure disposal procedures for hardware containing personal information
• Video surveillance and visitor access logging for all facilities containing personal information

9.2 Data Breach Response Procedures

In the unlikely event of a data security incident or breach involving your personal information, BallDraft / Hunger Madra LLC will:

• Conduct immediate investigation and containment of the incident
• Notify affected users within seventy-two (72) hours of discovery when required by law
• Coordinate with relevant authorities and regulatory bodies as required
• Implement additional security measures to prevent future incidents
• Provide credit monitoring or identity protection services if appropriate
• Maintain detailed incident logs and post-incident analysis reports

9.3 User Security Responsibilities

While BallDraft / Hunger Madra LLC implements robust security measures, you also play a critical role in protecting your personal information:

• Choose strong, unique passwords and enable two-factor authentication when available
• Never share your account credentials with third parties
• Log out of your account when using shared or public computers
• Monitor your account regularly for unauthorized activity
• Report suspected security incidents or unusual account activity immediately
• Keep your contact information current to receive important security notifications

10. CHILDREN'S PRIVACY PROTECTION

10.1 Age Restrictions and Enforcement

BallDraft / Hunger Madra LLC strictly prohibits access to our Platform by individuals under eighteen (18) years of age. We do not knowingly collect, process, or retain personal information from children or minors. Our age verification procedures include:

• Mandatory age declaration during account registration
• Identity document verification requiring government-issued photo identification
• Algorithmic detection of potentially underage users based on behavioral patterns
• Regular audits of user accounts to identify and remove underage users

10.2 Parental Rights and Responsibilities

If you are a parent or guardian and believe that your child has provided personal information to BallDraft / Hunger Madra LLC, please contact us immediately using the contact information provided in this Policy. Upon verification of parental identity and the child's unauthorized access, we will:

• Immediately suspend or terminate the child's account
• Delete all personal information collected from the child
• Implement additional measures to prevent future unauthorized access
• Cooperate with parents or guardians regarding any concerns or questions

10.3 Educational and Awareness Measures

BallDraft / Hunger Madra LLC may implement educational measures to raise awareness about age restrictions and the importance of parental supervision in online activities, including:

• Clear age warnings and disclaimers throughout the Platform
• Educational content about responsible gaming and age-appropriate online behavior
• Collaboration with industry organizations to promote youth protection initiatives

11. THIRD-PARTY SERVICES AND INTEGRATIONS

11.1 Third-Party Service Providers

Our Platform may integrate with or utilize services provided by third-party organizations, each of which may have their own privacy policies and data handling practices. These third parties include:

Payment Service Providers:

Financial institutions, payment processors, and digital wallet providers that facilitate monetary transactions on our Platform maintain their own privacy policies governing the collection and use of your financial information.

Analytics and Performance Monitoring:

Third-party analytics services help us understand Platform usage patterns and user behavior. These services may collect information about your interactions with our Platform and other websites.

Customer Support Tools:

Third-party customer service platforms and communication tools may process your support requests and maintain records of our interactions.

Sports Data and Content Providers:

Third-party sports data feeds and content providers supply real-time statistics, scores, and other sports-related information used in our contests.

11.2 Social Media Integration

If you choose to connect your BallDraft / Hunger Madra LLC account with social media platforms, we may collect information from these platforms in accordance with their respective privacy policies and your privacy settings. This may include profile information, friend lists, and social media activity.

11.3 Third-Party Privacy Policies

BallDraft / Hunger Madra LLC is not responsible for the privacy practices or content of third-party websites, applications, or services. We encourage you to review the privacy policies of any third-party services you use in connection with our Platform.

12. COOKIES AND TRACKING TECHNOLOGIES

12.1 Types of Cookies Used

BallDraft / Hunger Madra LLC uses various types of cookies and similar tracking technologies to enhance your Platform experience:

Essential Cookies:

Necessary for basic Platform functionality, including user authentication, session management, and security features. These cookies cannot be disabled without affecting Platform performance.

Performance and Analytics Cookies:

Collect information about how you use our Platform, including pages visited, time spent on the Platform, and error messages encountered. This information helps us improve Platform performance and user experience.

Functional Cookies:

Remember your preferences and settings to personalize your Platform experience, including language preferences, display settings, and customized content.

Advertising and Marketing Cookies:

Track your browsing behavior to deliver targeted advertising and measure the effectiveness of our marketing campaigns across various channels.

12.2 Cookie Management Options

You can manage cookie preferences through:

• Browser settings to accept, reject, or delete cookies
• Platform privacy settings to control specific cookie categories
• Third-party opt-out tools provided by advertising networks
• Industry opt-out mechanisms such as the Digital Advertising Alliance opt-out page

12.3 Consequences of Disabling Cookies

Disabling certain cookies may affect Platform functionality, including:

• Inability to maintain login sessions
• Loss of personalized settings and preferences
• Reduced Platform performance and user experience
• Limited access to certain Platform features and services

13. UPDATES AND MODIFICATIONS TO PRIVACY POLICY

13.1 Policy Updates

BallDraft / Hunger Madra LLC reserves the right to update, modify, or revise this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Material changes to this Policy will be communicated through:

• Prominent notice on our Platform homepage
• Email notification to registered users
• In-app notifications and alerts
• Updated effective dates and change summaries

13.2 Continued Use Constitutes Acceptance

Your continued use of the BallDraft / Hunger Madra LLC Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms and practices described therein. If you do not agree with any changes to this Policy, you must discontinue use of our Platform and may request deletion of your personal information subject to legal retention requirements.

14. DISPUTE RESOLUTION AND ARBITRATION

14.1 Mandatory Arbitration for Privacy Disputes

ALL DISPUTES, CLAIMS, OR CONTROVERSIES ARISING OUT OF OR RELATING TO THIS PRIVACY POLICY, OUR COLLECTION OR USE OF YOUR PERSONAL INFORMATION, OR ANY ALLEGED PRIVACY VIOLATIONS SHALL BE RESOLVED EXCLUSIVELY THROUGH BINDING ARBITRATION CONDUCTED OUT OF COURT IN ACCORDANCE WITH THE ARBITRATION PROVISIONS SET FORTH IN OUR TERMS AND CONDITIONS, WHICH ARE HEREBY INCORPORATED BY REFERENCE IN THEIR ENTIRETY.

14.2 Arbitration Procedures for Privacy Claims

Privacy-related arbitration proceedings shall be conducted in accordance with the Arbitration and Conciliation Act of Nigeria and the rules of the Lagos Court of Arbitration. The arbitration shall take place in Lagos State, Nigeria, and shall be conducted by a single arbitrator with demonstrated expertise in privacy law and data protection matters.

14.3 Class Action Waiver for Privacy Claims

YOU AGREE THAT YOU MAY BRING PRIVACY-RELATED CLAIMS AGAINST BALLDRAFT / HUNGER MADRA LLC ONLY IN YOUR INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS ACTION, COLLECTIVE ACTION, OR OTHER REPRESENTATIVE PROCEEDING RELATED TO PRIVACY OR DATA PROTECTION MATTERS.

15. CONTACT INFORMATION AND DATA PROTECTION OFFICER

15.1 Privacy Inquiries and Requests

For questions, concerns, requests, or complaints regarding this Privacy Policy or our data handling practices, please contact BallDraft / Hunger Madra LLC through the following channels:

15.2 Data Protection Officer

BallDraft / Hunger Madra LLC has appointed a qualified Data Protection Officer (DPO) to oversee our privacy and data protection program. You may contact our DPO directly regarding:

• Privacy rights and requests
• Data protection compliance questions
• Privacy impact assessments
• Data breach notifications and incident reports

15.3 Response Timeframes

BallDraft / Hunger Madra LLC will respond to privacy inquiries and requests within thirty (30) days of receipt, or such shorter period as may be required by applicable law. Complex requests may require additional time, and we will notify you of any delays and provide estimated completion timeframes.

16. REGULATORY COMPLIANCE AND LEGAL FRAMEWORK

16.1 Nigerian Data Protection Regulation (NDPR) Compliance

This Privacy Policy and our data handling practices comply with the Nigeria Data Protection Regulation (NDPR) 2019 and its implementation framework. Our compliance measures include:

• Lawful basis identification for all data processing activities
• Data protection impact assessments for high-risk processing
• Regular compliance audits and internal assessments
• Staff training on NDPR requirements and best practices
• Appointment of qualified data protection personnel

16.2 International Privacy Standards

While primarily governed by Nigerian law, BallDraft / Hunger Madra LLC also implements privacy practices consistent with international standards and best practices, including principles derived from:

• General Data Protection Regulation (GDPR) framework for European users
• California Consumer Privacy Act (CCPA) principles for transparency and user rights
• Asia-Pacific Economic Cooperation (APEC) Privacy Framework
• International Organization for Standardization (ISO) 27001 and 27002 standards

16.3 Regulatory Reporting and Cooperation

BallDraft / Hunger Madra LLC maintains cooperative relationships with relevant regulatory authorities and will:

• Report data breaches to appropriate authorities as required by law
• Cooperate with regulatory investigations and compliance reviews
• Participate in industry initiatives to promote privacy protection
• Maintain current registration and compliance with applicable data protection authorities

17. SPECIAL PROVISIONS FOR FINANCIAL INFORMATION

17.1 Enhanced Protection for Financial Data

Given the sensitive nature of financial information processed through our Platform, BallDraft / Hunger Madra LLC implements enhanced protection measures for all financial and payment-related data, including:

17.2 Financial Privacy Rights

With respect to your financial information, you have additional rights including:

• Right to receive detailed transaction histories and account statements
• Right to dispute unauthorized transactions and request investigations
• Right to request freezing of accounts pending resolution of security concerns
• Right to receive notification of suspicious activity or security incidents affecting your financial information

18. AGE VERIFICATION AND PROTECTION MEASURES

18.1 Comprehensive Age Verification

As our Platform is restricted to individuals eighteen (18) years of age and older, BallDraft / Hunger Madra LLC implements comprehensive age verification measures:

18.2 Underage Access Prevention

BallDraft / Hunger Madra LLC employs multiple layers of protection to prevent underage access:

• Age declaration requirements with legal attestations and penalties for false statements
• Device and browser fingerprinting to identify potentially shared or family devices
• Behavioral analysis to identify usage patterns consistent with underage users
• Third-party age verification services and databases
• Regular audits of user accounts and suspicious activity investigations

19. GOVERNING LAW AND LEGAL JURISDICTION

19.1 Applicable Privacy Laws

This Privacy Policy and our data processing activities are governed by the laws of the Federal Republic of Nigeria, including but not limited to:

• Nigeria Data Protection Regulation (NDPR) 2019
• Cybercrime (Prohibition, Prevention, etc.) Act 2015
• Freedom of Information Act 2011
• Constitution of the Federal Republic of Nigeria 1999 (as amended)
• Any other applicable federal, state, or local privacy and data protection legislation

19.2 Dispute Resolution for Privacy Matters

ALL DISPUTES, CLAIMS, OR CONTROVERSIES ARISING OUT OF OR RELATING TO THIS PRIVACY POLICY, OUR COLLECTION, USE, OR PROCESSING OF YOUR PERSONAL INFORMATION, OR ANY ALLEGED PRIVACY VIOLATIONS SHALL BE RESOLVED EXCLUSIVELY THROUGH BINDING ARBITRATION CONDUCTED IN LAGOS STATE, NIGERIA, IN ACCORDANCE WITH THE ARBITRATION PROVISIONS SET FORTH IN OUR TERMS AND CONDITIONS.

19.3 Regulatory Authority and Oversight

BallDraft / Hunger Madra LLC acknowledges the authority of the National Information Technology Development Agency (NITDA) and other relevant Nigerian regulatory bodies in matters relating to data protection and privacy compliance. We commit to:

• Cooperating fully with regulatory investigations and compliance reviews
• Implementing recommended corrective measures and improvements
• Maintaining current registration and compliance status with applicable authorities
• Participating in industry best practice initiatives and self-regulatory programs

20. EFFECTIVE DATE AND ACKNOWLEDGMENT

This Privacy Policy is effective as of September 02, 2025, and supersedes all previous versions. By using the BallDraft / Hunger Madra LLC Platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

For questions or concerns regarding this Privacy Policy, please contact us using the information provided in Section 15.