Privacy Policy

1. Who We Are

The Website is operated by Punch Gaming Inc., a corporation incorporated in Delaware, United States, and its parent company Punch Gaming Ltd., incorporated under the laws of Israel (together, the "Company"). Punch Gaming Inc. is the primary data controller for personal information collected through this Website. Punch Gaming Ltd. may process personal data on behalf of Punch Gaming Inc. as a data processor, subject to appropriate data processing agreements.

The Company operates in the digital collectibles and gaming-adjacent industry. This Website is a corporate information site only and does not provide, offer, or facilitate any gaming, wagering, sweepstakes, or consumer services directly. Any such services are governed by separate terms and policies on the applicable platform.

2. Scope of This Policy

This Privacy Policy applies solely to personal information collected through punchgaming.co. It applies to all visitors regardless of location, including residents of the United States, the European Economic Area, and Israel. By using this Website, you acknowledge that your information will be processed in accordance with this Policy.

3. Information We Collect

We collect information in the following ways:

Information you provide directly:

• Contact form submissions: full name, email address, phone number, and message content.

Information collected automatically:

• Technical data: IP address, browser type and version, device type and model, operating system, referring URLs, and pages visited.
• Analytics data: session duration, click patterns, and general usage behavior collected through analytics tools.
• Approximate location derived from IP address.

We do not collect sensitive personal information (such as government ID numbers, financial account details, health data, or biometric data) through this Website.

4. How We Use Your Information

We use the information we collect for the following purposes:

• To respond to your inquiry submitted through the contact form.
• To improve and maintain the Website's performance and user experience.
• To analyze how visitors interact with the Website through aggregated analytics.
• To comply with applicable legal obligations.
• To protect the rights, property, and safety of the Company and its users.

We will not use your personal information for marketing or promotional communications without your separate explicit consent.

5. Legal Basis for Processing

We process your personal information on the following legal bases:

• Consent: for contact form submissions, given at the time of submission. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Legitimate interest: for analytics and technical data, to understand and improve website performance. You may object to this processing at any time.
• Legal obligation: where processing is required to comply with applicable law.

6. Cookies and Tracking Technologies

This Website may use cookies and similar tracking technologies to collect analytics data. If any cookie collects personal information, you will be informed at the point of collection. You may control or disable cookies at any time through your browser settings. Disabling cookies may affect certain Website functionality.

Do Not Track:

Some browsers transmit a "Do Not Track" (DNT) signal requesting that websites refrain from tracking browsing activity. There is currently no uniform industry or legal standard governing how DNT signals must be interpreted. We do not currently alter our data collection practices in response to DNT signals. If a binding standard is established, we will update this Policy accordingly. For more information about DNT, visit www.allaboutdnt.com.

7. How Long We Keep Your Data

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, to comply with our legal obligations, resolve disputes, and enforce our agreements. The appropriate retention period is determined based on the nature of the information, the purpose for which it was collected, and applicable legal requirements. When personal information is no longer needed, we securely delete or anonymize it.

8. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties.

We may share your information in the following limited circumstances:

• Service providers: with vendors who assist us in operating the Website or managing inquiries (such as email platforms, hosting providers, or analytics tools). These providers are contractually bound to process data only on our instructions and in compliance with applicable law.
• Corporate affiliates: between Punch Gaming Inc. and Punch Gaming Ltd. as necessary for the operation of the business, subject to appropriate safeguards.
• Legal requirements: if required to do so by law, court order, subpoena, or a competent governmental or regulatory authority.
• Business transfers: in connection with a merger, acquisition, asset sale, or other business transaction, in which case your information may be transferred to the acquiring entity, subject to the same protections described in this Policy.
• Safety and security: to protect the rights, property, or safety of the Company, its users, or others.

9. International Data Transfers

This Website is operated jointly from the United States and Israel. Your personal information may be transferred to and processed in both countries.

• Israel: Israel has received an adequacy decision from the European Commission and is recognized as providing an adequate level of data protection for transfers from the European Economic Area.
• United States: The US does not have a general adequacy decision from the European Commission. If you are located in the EEA and your data is transferred to the US, we will ensure appropriate safeguards are in place, such as standard contractual clauses (SCCs), prior to the transfer.

By submitting information through this Website, you acknowledge and consent to the transfer of your information to these jurisdictions.

10. Data Security and Breach Notification

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, loss, alteration, disclosure, or destruction. Access to personal data is restricted to authorized personnel only on a need-to-know basis.

Despite these measures, no data transmission over the internet or electronic storage system is completely secure. We cannot guarantee absolute security.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority without undue delay and, where required by applicable law, notify affected individuals directly.

11. Your Rights

Depending on your location, you may have the following rights regarding your personal information. To exercise any of these rights, contact us at support@punchgaming.co. We will respond within 45 days of receipt of your request.

• Access: request a copy of the personal information we hold about you.
• Correction: request that inaccurate or incomplete data be corrected.
• Deletion: request that we delete your personal information, subject to any legal obligations requiring retention.
• Objection: object to processing based on legitimate interest.
• Restriction: request that we restrict processing of your data in certain circumstances.
• Portability: request a copy of your data in a structured, machine-readable format (where applicable).
• Withdrawal of consent: withdraw consent at any time for processing based on consent.
• Complaint: lodge a complaint with a supervisory authority. In the US, you may contact the relevant state attorney general. In Israel, contact the Privacy Protection Authority (PPA) at www.gov.il/en/departments/the_privacy_protection_authority. In the EEA, contact your local data protection authority.

We will not discriminate against you for exercising any of your privacy rights.

12. California Residents

If you are a California resident, the California Online Privacy Protection Act (CalOPPA) and, where applicable, the California Consumer Privacy Act (CCPA/CPRA) grant you additional rights.

CalOPPA rights:

• You have the right to know what categories of personal information we collect and with whom we share it.
• You have the right to request access to, correction of, and deletion of your personal information.
• To submit a request, contact us at support@punchgaming.co.

CCPA/CPRA rights (where applicable):

• Right to know: you may request disclosure of the categories and specific pieces of personal information we have collected about you in the past 12 months.
• Right to delete: you may request deletion of personal information we have collected about you, subject to certain exceptions.
• Right to correct: you may request correction of inaccurate personal information.
• Right to opt out of sale or sharing: we do not sell your personal information and do not share it for cross-context behavioral advertising purposes.
• Right to non-discrimination: we will not discriminate against you for exercising any of your CCPA rights.

To submit a verifiable consumer request, contact us at support@punchgaming.co. You may also designate an authorized agent to make a request on your behalf by providing written authorization. We will respond within 45 days. If additional time is needed (up to 90 days total), we will notify you in writing of the reason and extension period.

13. Israeli Residents

If you are an Israeli resident, your personal information is protected under Israel's Protection of Privacy Law, 5741-1981, as amended by Amendment 13 (effective August 14, 2025). In addition to the rights described in Section 11, you have the right to lodge a complaint with the Privacy Protection Authority (PPA).

As required under Israeli law, we take reasonable measures to ensure the security of personal data and notify the PPA and affected individuals in the event of a qualifying data breach.

14. Children's Privacy

This Website is not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have collected personal information from a person under 18 without parental consent, we will take steps to delete that information promptly. If you believe we have inadvertently collected such information, please contact us at support@punchgaming.co.

15. Third-Party Websites and Links

This Website may contain links to websites operated by third parties that are not owned or controlled by the Company. These links are provided for convenience only. We have no control over the content, privacy practices, or availability of such third-party sites and accept no responsibility or liability for them. The inclusion of any link does not imply endorsement. This section does not apply to websites owned or operated by the Company or its affiliates.

16. Changes to This Policy

We may update this Privacy Policy from time to time. The effective date at the top of this page reflects the date of the most recent revision. For material changes, we will take reasonable steps to bring the update to your attention. Continued use of the Website following any update constitutes acceptance of the revised Policy.

17. Contact

For any questions, requests, or complaints relating to this Privacy Policy, please contact us at:

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