PRIVACY POLICY

Ages 13–17

Effective: May 29, 2026

Operator: Marbula One LLC

Privacy Contact: legal@marbulaone.com

This Privacy Policy (“Policy”) describes how Marbula One LLC (“Marbula One,” “we,” “us,” or “our”) collects, uses, and shares personal information when you use the Marbula One platform, website, and related services available at game.marbulaone.com and any associated pages (collectively, the “Platform”).

This Policy applies to users of the Platform who are between the ages of 13 and 17. The Platform is intentionally designed with minimal data collection to protect young users’ privacy. A separate Marbula One service is available at game.racino.io for users 18 and older, under its own terms and privacy policy.

If you are a parent or guardian, this Policy describes the information we collect about your child and the choices you have. You may contact us at legal@marbulaone.com at any time with questions or requests relating to your child’s information.

By using the Platform, you agree to the practices described in this Policy. If you do not agree, please do not use the Platform.

1. Children Under 13

The Platform is not directed to, and may not be used by, any person under the age of 13. We do not knowingly collect personal information from any child under 13. If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will delete that information promptly and terminate the associated account.

If you believe a child under 13 has provided personal information to the Platform, please contact us at legal@marbulaone.com.

2. Information We Collect

2.1 Information You Provide

We intentionally minimize the personal information we collect from users of this Platform. When you create an account, we collect:

- Username, email address, and date of birth or age confirmation;

- Correspondence records if you contact us for support;

- When a purchase is made: billing information (including name, billing address, and email) necessary to process the transaction. Payment card details are submitted directly to our third-party payment processor and are not stored on our servers.

2.2 Information We Do Not Collect

We do not collect, process, or store the following types of information from users of this Platform:

- Government-issued identification, full legal name, or tax identification number;

- Precise geolocation data;

- Wallet, cryptocurrency, or other digital-asset data;

- Financial information beyond what is necessary to process a single purchase, which is handled by our third-party payment processor.

2.3 Automatically Collected Information

We automatically collect certain technical information when you use the Platform, including device type and operating system, browser type and version, IP address (used to derive approximate geographic location for fraud-prevention purposes), and information about how you interact with the Platform and our communications.

3. How We Use the Information We Collect

We use personal information for the following purposes:

- To create and manage your account and provide Platform features;

- To process purchases of in-Platform items;

- To verify your age and detect duplicate accounts;

- To detect, prevent, and investigate fraud, cheating, and prohibited conduct;

- To respond to support requests and communications;

- To send transactional communications (account notices, security alerts, policy updates);

- To analyze and improve Platform performance and user experience;

- To comply with legal obligations and protect our legal rights and the rights of others.

We do not use Platform user data to build user profiles for advertising. We do not use Platform user data for interest-based or behavioral advertising. Where technically feasible, we disable or restrict third-party analytics and tracking technologies on Platform surfaces.

4. How We Share Your Information

We do not sell your personal information. We share your information only as described below.

4.1 Service Providers

We share data with third-party vendors that perform services on our behalf, with cloud hosting providers, payment processors, and customer support platforms. These providers are contractually restricted from using your information for any purpose other than providing services to us.

4.2 No Sharing for Advertising

We do not share personal information of Platform users with advertising networks, data brokers, or third-party marketing platforms for any purpose. We do not sell or share the personal information of users we know to be under 18 for cross-context behavioral advertising.

4.3 Legal and Regulatory Authorities

We may disclose your information to government agencies, regulators, or law enforcement where required by law, court order, legal process, or to protect the rights, property, or safety of Marbula One LLC, our users, or the public.

4.4 Business Transfers

In connection with a merger, acquisition, financing, restructuring, or sale of all or a portion of our business, your information may be transferred to the successor entity, subject to the same protections described in this Policy.

4.5 With Your Consent

For any purpose not described above, we will share your information only with your prior consent (or, where applicable, the consent of a parent or guardian).

5. Parental Rights and Choices

Parents or guardians of users on the Platform may exercise the following rights with respect to their child’s personal information:

- Access — request a copy of the personal information we have collected about the child;

- Correction — request that we correct any inaccurate or incomplete personal information;

- Deletion — request that we delete the child’s personal information, subject to legal retention obligations;

- Account closure — request that we close the child’s account.

To exercise any of these rights, contact us at legal@marbulaone.com. We will respond to verified requests within 30 days. Proof of relationship may be required before we process a parental request.

6. Your Rights and Choices

6.1 Marketing Communications

We do not send marketing communications to Platform users. You will only receive transactional communications relating to your account (such as account notices, security alerts, and policy updates).

6.2 Exercising Your Rights

To exercise privacy rights or ask a question about your information, contact us at legal@marbulaone.com. We may need to verify your identity (or, for a parental request, proof of relationship) before processing your request. We will respond within 30 days, or within the timeframe required by applicable law.

7. Cookies and Tracking Technologies

We use cookies and similar technologies to operate the Platform, authenticate users, and remember preferences. Some cookies are essential to Platform function. You may opt out of non-essential cookies through your browser settings or by enabling a Global Privacy Control (GPC) signal, which we will honor.

We do not use Platform user data to build user profiles or serve interest-based advertising. We do not share Platform user data with advertising networks or data brokers. Where technically feasible, we disable or restrict third-party analytics and tracking technologies on pages and flows reserved for Platform users.

8. Data Retention

We retain personal information for the following periods:

- Account data: for the duration of the account plus 3 years following account closure, unless a longer period is required by law;

- Purchase records: minimum 5 years from each transaction, for tax, accounting, and business recordkeeping purposes;

- Tax records: minimum 7 years, or as required by applicable federal and state tax law;

- Automatically collected data (device, IP, cookies): up to 13 months from collection, unless required for an active dispute or investigation;

- Communications and support records: up to 3 years from the date of the communication.

We may retain information beyond these periods where necessary to resolve disputes, enforce our agreements, or comply with a legal obligation. We may retain anonymized or aggregated data indefinitely.

9. Security

We maintain industry-standard technical and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. No security system is completely impenetrable, and we cannot guarantee the absolute security of personal information. In the event of a data breach that affects your rights, we will notify you without undue delay, and in no event more than 72 hours after we become aware of the breach where GDPR or UK GDPR applies, or within the period required by applicable state or national law, whichever is sooner. Notice will be provided by email to the address on the account and, where required, to the relevant supervisory authority.

10. International Data Transfers

We operate in the United States and may process your information on servers located in the United States or in other countries. If you are located in the European Economic Area (EEA) or United Kingdom, personal information transferred outside those regions will be protected by appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission or the UK Information Commissioner’s Office, or other legally recognized transfer mechanisms.

11. State-Specific Privacy Rights (United States)

11.1 California (CCPA/CPRA)

California residents have the right to know, access, correct, delete, and opt out of the sale or sharing of their personal information. We do not sell personal information. We do not share the personal information of users under 18 for cross-context behavioral advertising. To exercise your California privacy rights, contact us at legal@marbulaone.com.

11.2 Other U.S. States

Residents of Virginia, Colorado, Connecticut, Texas, and other states with comprehensive privacy laws have rights to access, correct, delete, and port their personal information, and to opt out of targeted advertising and certain profiling. Contact us at legal@marbulaone.com to submit a request.

12. Legal Bases for Processing (EEA and UK Users)

If you are located in the EEA or UK, we process your personal information on the following legal bases:

- Contract: to perform our agreement with you, including account services and purchases;

- Legal obligation: to comply with tax and other applicable legal requirements;

- Legitimate interests: to detect fraud, improve the Platform, and ensure Platform security, where not overridden by your interests;

- Consent: where we have asked for and received your consent (or, where applicable, the consent of a parent or guardian).

You may withdraw consent at any time by contacting us at legal@marbulaone.com. EEA and UK users may lodge complaints with their local supervisory authority. A list of EU supervisory authorities is available at https://edpb.europa.eu. The UK supervisory authority may be contacted at https://ico.org.uk.

13. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will notify you by email or by posting a prominent notice on the Platform before the changes take effect. Your continued use of the Platform after the effective date of any update constitutes your acceptance of the updated Policy.

14. Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or wish to make a parental request, please contact us:

Marbula One LLC

975 E Maple Rd, Suite 100

Birmingham, MI 48009

Email: legal@marbulaone.com