1. WHO WE ARE

1.1. Bullet is a brand owned by BULLET PAYMENTS AND FINANCIAL SERVICES LTD., a limited liability company, headquartered in the city of Vancouver, State of British Columbia - BC, at 578-2912 WEST BROADWAY, ZIP Code V6K0E9, Canada, registered under No. BC1506717, the data controller responsible for the processing of your personal data. The Bullet platform is made available exclusively through the URL: https://bullet.cash.

1.2. To ensure transparency and accuracy in its rules, Bullet may amend this Privacy Policy at any
time. If any changes are made, you will be notified via email and/or through publication on our App. If you do not agree with the changes, you must stop accessing the site and using Bullet's services. If you continue to access the site and use the services after such changes, you accept and agree with the updated terms of the Privacy Policy.

1.3. If you have any questions about this Privacy Policy or about the processing of Personal Data,
please contact us at [email protected], addressed to our Data Protection Officer (DPO). 

2. HOW DOES REGISTRATION WITH BULLET WORKS?

2.1. Bullet collects the necessary personal data, as listed below, in order to properly provide its features and comply with legal obligations. When you register and use the Services, you provide Bullet with personal data, which will be processed in accordance with this Privacy Policy and may be used in the situations and for the purposes described herein.

2.2. Users under 18 (eighteen) years of age must not use Bullet. If we become aware of registrations made by underage individuals, their personal data will be deleted from our databases and their
accounts will be cancelled.

3. WHAT PERSONAL DATA IS COLLECTED?

3.1. Bullet may collect your information in various circumstances:

(a) To register on Bullets's App, you voluntarily submit and expressly authorize Bullet to collect and process personal data such as: (i) full name; (ii) taxpayer identification number; (iii) email address; (iv) phone number; (v) date of birth, and (vi) full address.

(b) For services or transactions involving additional legal and regulatory obligations, further personal data may be required, such as: (i) copy of driver's license, ID card or other identification document; (ii) proof of address; (iii) user photo (selfie); (iv) proof of income and tax returns, including income tax filings; (v) other data and documents required by authorities and regulatory bodies.

(c) To enable financial transactions, we may request banking data, such as: (i) proof of relationship with financial institutions; (ii) identification of financial institutions, branches, and bank accounts; (iii) PIX transfer keys; and (iv) other data necessary to carry out transactions.

(d) For registration and participation in exclusive promotions offered by Bullet, including nickname data from the platforms.

3.2. Bullet is not responsible for the accuracy, untruthfulness, or outdated information you provide,
but we commit to correcting them upon request, as defined by law.

3.3. This policy does not apply when you click on a link and are redirected to third-party websites, partners of Bullet. In such cases, we recommend that you read the privacy policy of the third-party website before providing any personal data.

4. WHAT TECHNICAL DATA IS COLLECTED?

4.1. You also authorize the collection of the following technical information: (i) access IP; (ii) access
time; (iii) date and time of access; (iv) device type; (v) pages visited; (vi) language used; (vii) your
location; (viii) roaming tracking; (ix) software crash reports; and (x) browser type.

4.2. We use anonymized personal data to produce statistics, studies, research, project planning, and surveys relevant to Bullet's services and user behavior. We also use anonymized data to manage risks and detect, prevent, and/or remedy fraud or other potentially illegal or prohibited activities, in accordance with applicable terms of use.

4.3. For the purpose of promoting Bullet's products and services, upon registration you may choose whether or not to authorize the use of your data for this purpose, ensuring that your consent is freely, informed, and unequivocally given. If you agree to receive marketing, you may opt out at any
time by contacting Bullet.

4.4. In addition to the data provided for the purposes described above, you also authorize Bullet to
use your preferences to notify you about new services that may be of interest.

5. WHAT IS THE PURPOSE OF DATA PROCESSING?

5.1. When you contract Bullet, you provide the personal data necessary to enable the operation and
provision of Services. We also collect data to comply with legal obligations, based on your consent, and to meet Bullet's legitimate interests.

5.2. Whenever there is a change in the purpose of data processing that is not compatible with the original consent, you will be informed in advance and may revoke your consent if you do not agree. Bullet only processes personal data when there is a legal basis to do so.

5.3. The data indicated in item 3 is used by Bullet exclusively for: (i) identifying you and validating the data provided; (ii) enabling financial transactions between you and Bullet; (iii) including your data in Bullet's services/products; (iv) properly providing the service; (v) billing; (vi) contacting you to address requests and inquiries; (vii) assessing whether you are over 18 years of age and eligible to use Bullet; and (viii) contacting you regarding Bullet's services and third-party services that may be
of interest.

5.4. The data listed in items 3 and 4, including payment and financial transaction data, are used exclusively for: (i) improving your user experience; (ii) validating your identity, ensuring security, conducting risk analyses, and fraud checks, among other related activities; (iii) complying with regulatory obligations, including customer identification, anti-money laundering, or counter-terrorism financing; (iv) serving Bullet's legitimate interests in delivering its services.

5.5. In addition to the purposes and legal bases described above, some activities will only be carried out with your consent, such as promoting Bullet and third-party products and services. At
registration or at any time while being a User, you may opt to authorize or not authorize the use of your data for this purpose.

5.6. Processing will be carried out in compliance with the law and will end when: (i) the purpose has been achieved or is no longer necessary; (ii) the processing period has expired; (iii) you request its termination; or (iv) by order of competent authorities.

5.7. While processing is ongoing, all personal data provided to Bullet will: (i) be stored in a reserved database with controlled and restricted access to authorized staff, all bound to confidentiality obligations; (ii) be used solely for the purposes for which you consented or were informed; and (iii) comply with applicable legal provisions.

6. CAN MY PERSONAL DATA BE SHARED?

6.1. To carry out financial transactions with Banks and payment service providers, Bullet may share
data and maintain transaction records.

6.2. Bullet may also share data to comply with public authority and/or regulatory requirements. Data may also be shared with third parties to enforce our terms of use and any other contract, in
line with our legitimate interest.

6.3. Bullet may share personal data with service partners to enable contracted services, such as loyalty program management and tournament organization.

6.4. If you request correction, deletion, anonymization, blocking of data, and/or withdrawal of
consent, we will inform our partner companies with whom your personal data has been shared so
that they may take the requested action.

7. DATA SUBJECTS' RIGHTS

7.1. As the holder of your personal data, you may, at any time and by written request: (i) confirm the existence of processing; (ii) access your data; (iii) correct incomplete, inaccurate, or outdated data; (iv) anonymize, block, or delete unnecessary, excessive, or unlawfully processed data; (v) transfer your personal data to another service provider; (vi) delete personal data processed with your consent; (vii) obtain information about public and private entities with which we share data; (viii) obtain information about the possibility of refusing consent and its consequences; and (ix) revoke consent for personal data processing.

7.2. There may be cases in which your request cannot be fulfilled (for example, we may retain and use data processed with consent as permitted by law), in which case you will be informed of the reason and provided with the contact responsible.

7.3. If you wish to exercise any of the above rights, or in case of doubts, suggestions, or complaints, you may contact us at [email protected]. Your account will be terminated after your data has been deleted. We will maintain records of communications with you as required by public authorities or competent bodies, including for legal defense purposes.

8. SECURITY PRECAUTIONS FOR USER PROTECTION

8.1. Bullet will always take appropriate technical and organizational measures to protect your personal data to the fullest extent possible. Various market-standard security measures are adopted
to protect your information, which will be stored in a secure and confidential database.

8.2. Your account will be protected by credentials chosen by you so that only you can access your personal information and Bullet account. Since the password is confidential, Bullet advises you to
keep it secure and never share it, ensuring that access is exclusively yours. You acknowledge that
you are solely responsible for managing your access credentials.

8.3. Use strong passwords, and avoid accessing your account on third-party devices or public
networks. Bullet will never request your password or access PIN, nor send you executable files for download. Bullet cannot be held responsible for unauthorized access resulting from user negligence.

8.4. The functioning and security of the devices and networks you use to access our Services are
your sole responsibility. To ensure a secure environment, we recommend taking reasonable security precautions (such as using antivirus software, in addition to the measures suggested by device manufacturers and software providers). If you suspect your personal data is at risk, contact our support channels for assistance.