PRIVACY POLICY.

KG ARMY NPC ("KG ARMY", "we", "us" or "our") is a non-profit company registered in the Republic of South Africa.

The name "KG" refers to "Kak Groot", which forms part of the identity and branding of KG ARMY.

KG ARMY operates a competitive gaming platform where eligible players may participate in skill-based gaming competitions. Certain competitions may require players to pay an entry fee, with prizes awarded to qualifying winners in accordance with the applicable competition rules and Terms and Conditions.

Any surplus generated through the activities of KG ARMY is applied in accordance with the objectives of the NPC, including supporting charitable or community causes where applicable and in accordance with South African law.

For purposes of POPIA, KG ARMY NPC is the Responsible Party in respect of personal information that it processes.

We respect your privacy and are committed to processing personal information lawfully, responsibly and transparently.

Depending on how you use our website, platform and services, we may collect and process the following categories of personal information.

KG ARMY processes personal information for purposes connected with operating and administering our platform, competitions and organisation.

This may include:

• ▸Creating and managing user accounts;
• ▸Verifying account access through WhatsApp OTP or other verification mechanisms;
• ▸Processing and managing competition entries;
• ▸Recording game scores and results;
• ▸Operating public leaderboards;
• ▸Determining and verifying competition winners;
• ▸Administering and delivering prizes;
• ▸Processing payments and refunds;
• ▸Communicating with you regarding your account, competitions, payments and prizes;
• ▸Providing customer and technical support;
• ▸Detecting and preventing fraud, cheating, abuse and other prohibited conduct;
• ▸Maintaining the security and integrity of our platform;
• ▸Improving our website, platform and services;
• ▸Maintaining financial, accounting and administrative records;
• ▸Complying with legal and regulatory obligations;
• ▸Resolving disputes;
• ▸Enforcing our Terms and Conditions and competition rules;
• ▸Protecting the rights, property and legitimate interests of KG ARMY, our users and other persons; and
• ▸Supporting the lawful objectives and activities of KG ARMY NPC.

We will not process personal information for purposes that are incompatible with the purpose for which it was collected unless permitted by applicable law.

KG ARMY processes personal information in accordance with the conditions for lawful processing set out in POPIA.

Depending on the circumstances and the nature of the processing, KG ARMY may process personal information where:

• ▸The data subject has provided consent;
• ▸Processing is necessary to perform or take steps in relation to an agreement with the data subject;
• ▸Processing is necessary to comply with a legal obligation;
• ▸Processing protects a legitimate interest of the data subject;
• ▸Processing is necessary to protect a legitimate interest of KG ARMY or a third party, where permitted by POPIA;
• ▸Processing is necessary to protect a legitimate interest recognised by applicable law; or
• ▸Processing is otherwise permitted or required by applicable law.

Where processing is based on consent, you may withdraw that consent at any time, subject to applicable law.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Withdrawal of consent does not necessarily require KG ARMY to delete information that it is legally required or otherwise permitted to retain.

Certain information is necessary for KG ARMY to provide particular services.

For example, a valid mobile telephone number may be required to verify your account, while information relating to a payment may be necessary to process a competition entry.

Where information is required for participation in a competition or provision of a service, failure to provide the required information may prevent KG ARMY from:

• ▸Creating or verifying your account;
• ▸Accepting or administering your competition entry;
• ▸Contacting you;
• ▸Verifying your eligibility; or
• ▸Delivering a prize.

We aim to collect only personal information that is adequate, relevant and reasonably necessary for the applicable purpose.

KG ARMY may publish competition results through public leaderboards.

Publicly displayed information may include:

• ▸Your chosen callsign or gaming handle;
• ▸Your score;
• ▸Your ranking or position; and
• ▸Other competition-related results.

Your private mobile telephone number, payment-card information and other confidential account information will not intentionally be displayed on public leaderboards.

Because callsigns and competition results may be publicly visible, you are responsible for selecting a callsign that does not reveal personal information you do not wish to make public.

Where required by applicable law or the applicable competition rules, KG ARMY may also publish information concerning competition winners.

KG ARMY does not sell or rent your personal information.

We may share relevant personal information where reasonably necessary to operate the platform, administer competitions, process transactions, deliver prizes, comply with the law or protect legitimate interests.

This may include the following categories of recipients.

Where third-party service providers process personal information on behalf of KG ARMY, we take reasonable steps to ensure that they:

• ▸Process information only for authorised purposes;
• ▸Maintain confidentiality;
• ▸Implement appropriate security safeguards; and
• ▸Comply with applicable data-protection requirements.

Where required by POPIA, KG ARMY will enter into appropriate arrangements with operators or service providers that process personal information on its behalf.

KG ARMY remains responsible for fulfilling its obligations as the Responsible Party under POPIA.

Some of our technology, hosting, payment, communications or other service providers may operate outside South Africa or may process information outside South Africa.

Where personal information is transferred outside South Africa, KG ARMY will take reasonable steps to ensure that the transfer complies with the requirements of POPIA.

Where required by POPIA, KG ARMY will ensure that an appropriate legal basis or safeguard exists for the transfer, including where the recipient is subject to laws or agreements providing an adequate level of protection.

KG ARMY will not retain personal information for longer than is necessary for the purpose for which it was collected or subsequently processed, unless longer retention is required or permitted by law.

Different types of information may therefore be retained for different periods.

We may retain information where necessary for:

• ▸Active account administration;
• ▸Competition records;
• ▸Payment and transaction records;
• ▸Accounting and tax purposes;
• ▸Fraud prevention;
• ▸Security purposes;
• ▸Resolving disputes;
• ▸Enforcing agreements and competition rules;
• ▸Prize administration;
• ▸Legal or regulatory requirements; and
• ▸Protecting the legitimate interests of KG ARMY.

When personal information is no longer required and there is no lawful reason for retaining it, we will take reasonable steps to securely delete, destroy or de-identify it.

KG ARMY takes reasonable technical and organisational measures to protect personal information against unauthorised access, loss, damage, alteration, disclosure, destruction or unlawful processing.

Depending on the circumstances, these measures may include:

• ▸Encrypted data transmission;
• ▸Secure hosting and storage;
• ▸Authentication mechanisms;
• ▸Access controls;
• ▸Restricted access to personal information;
• ▸Security monitoring;
• ▸Backups and recovery procedures; and
• ▸Organisational security procedures.

Although we take reasonable steps to protect your information, no method of transmitting or storing information electronically can be guaranteed to be completely secure.

KG ARMY will take reasonable steps to detect, investigate and respond to suspected or actual security compromises involving personal information.

Where KG ARMY has reasonable grounds to believe that the personal information of a data subject has been accessed or acquired by an unauthorised person, KG ARMY will deal with the incident in accordance with POPIA and applicable law.

Where notification is required, KG ARMY will notify the Information Regulator and affected data subjects as required by law and within the applicable statutory requirements.

KG ARMY takes reasonably practicable steps to ensure that personal information in our possession is accurate, complete, not misleading and updated where necessary.

You are responsible for providing accurate information and should notify us if information associated with your account is incorrect or needs to be updated.

KG ARMY's platform and paid competitions are intended for persons 18 years of age or older.

Persons under the age of 18 are not eligible to participate in KG ARMY paid competitions unless expressly permitted by applicable law and the relevant competition rules.

KG ARMY does not knowingly collect or process personal information relating to children in circumstances prohibited by POPIA.

If KG ARMY becomes aware that personal information relating to a child has been collected or processed unlawfully, KG ARMY will take reasonable steps to address the situation, which may include deleting or destroying the information where legally appropriate.

Additional age and eligibility requirements may be contained in the applicable KG ARMY Terms and Conditions and Competition Rules.

KG ARMY may communicate with you regarding:

• ▸Your account;
• ▸Competition entries;
• ▸Payments;
• ▸Competition results;
• ▸Prizes;
• ▸Security matters;
• ▸Customer support; and
• ▸Other information necessary to administer our services.

These operational communications may be sent where reasonably necessary to provide our services or administer your relationship with KG ARMY.

Where KG ARMY sends direct marketing communications, we will comply with the direct-marketing requirements of POPIA and other applicable legislation.

Where consent is required for electronic direct marketing, KG ARMY will obtain the required consent and provide an appropriate means for you to withdraw that consent or opt out of future marketing communications.

Where permitted by applicable law, KG ARMY may send marketing communications to existing customers or users in accordance with the applicable requirements and opt-out provisions.

Our website or platform may use cookies and similar technologies to:

• ▸Operate the platform;
• ▸Maintain security;
• ▸Remember preferences;
• ▸Analyse platform usage;
• ▸Improve performance; and
• ▸Provide relevant functionality.

Where third-party analytics, advertising or similar technologies are used, additional information may be provided through a separate Cookie Policy or relevant notice.

KG ARMY will process information collected through cookies and similar technologies in accordance with applicable law.

Subject to the limitations and exceptions provided by law, you may have the right to:

• ▸Request confirmation as to whether KG ARMY holds personal information about you;
• ▸Request access to personal information held about you;
• ▸Request correction or updating of inaccurate, incomplete or misleading information;
• ▸Request deletion of personal information where permitted by law;
• ▸Object to certain processing of your personal information;
• ▸Withdraw consent where processing is based on consent;
• ▸Request information regarding the processing of your personal information; and
• ▸Lodge a complaint regarding the processing of your personal information.

Some requests may be subject to lawful limitations, identity-verification requirements or other requirements under POPIA.

Where KG ARMY is legally required to retain information, a request for deletion may not result in immediate deletion.

To protect personal information, KG ARMY may require reasonable verification of your identity before processing certain requests concerning your account or personal information.

This helps prevent unauthorised persons from accessing, changing or deleting another person's information.

KG ARMY will seek to use reasonable and proportionate verification measures for the particular request.

KG ARMY NPC has an appointed Information Officer responsible for assisting with privacy and information-protection matters and applicable access-to-information obligations.

Information Officer: Sean Harris

Email: sean@kgarmy.co.za

Physical/Postal Address: 2 Hamlet Road, House 7, South Africa

Requests relating to your personal information, privacy rights or privacy complaints should be directed to the Information Officer using the contact details above.

KG ARMY will endeavour to respond to legitimate requests within the timeframes required by applicable law.

If you believe that KG ARMY has processed your personal information unlawfully or has otherwise interfered with your rights under POPIA, you are encouraged to contact our Information Officer first so that we can investigate and attempt to resolve the matter.

You also have the right to lodge a complaint with the Information Regulator of South Africa in accordance with applicable law.

KG ARMY may update this Privacy Policy from time to time to reflect changes to:

• ▸Our services;
• ▸Our technology;
• ▸The personal information we process;
• ▸Our service providers;
• ▸Applicable legislation; or
• ▸Our privacy and security practices.

Where changes are material, we will take reasonable steps to notify users by publishing the updated Privacy Policy and updating the "Last Updated" date.

This Privacy Policy is governed by the laws of the Republic of South Africa, including the Protection of Personal Information Act 4 of 2013 and other applicable South African legislation.

For questions regarding this Privacy Policy, your personal information, your privacy rights or the processing of your personal information, please contact KG ARMY's Information Officer.

KG ARMY NPC

Republic of South Africa

Information Officer: Sean Harris

Email: sean@kgarmy.co.za

Address: 2 Hamlet Road, House 7