PRIVACY POLICY

1. Introduction

Last Updated: 10 March 2026
Effective Date: 10 March 2026

This Privacy Policy (“Policy”) explains how 98 Billiards Entertainment Limited (“we”, “us”, or “our”) collects, uses, stores, processes, discloses, and protects your personal information when you access or use our software, mobile applications, websites, and related services (collectively, the “Services”).

We are committed to protecting your privacy and complying with applicable laws in New Zealand, including the Privacy Act 2020. This Policy is designed to provide transparency about our practices and to help you understand your rights and choices regarding your personal information.

By accessing or using our Services, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. If you do not agree with this Policy, you must cease using the Services immediately.

If you are under the age of 18, you must only use the Services under the supervision of a parent or legal guardian who agrees to this Policy on your behalf.

2. Definitions

For the purposes of this Policy:

· Personal Information means any information about an identifiable individual, as defined under the Privacy Act 2020.

· Sensitive Personal Information includes information such as financial details, identification numbers, biometric data, and any data that requires a higher level of protection.

· Services refers to all products, applications, and services provided by 98 Billiards Entertainment Limited.

· Third Parties means external service providers, partners, or entities not directly controlled by us.

3. Our Privacy Principles

We adhere to the following principles when handling your personal information:

1. Purpose Limitation – We collect information only for specific, lawful purposes.

2. Data Minimisation – We collect only what is necessary.

3. Transparency – We clearly explain how data is used.

4. Security – We take reasonable steps to protect your data.

5. User Control – You have rights over your personal information.

6. Accountability – We are responsible for how your data is handled.

4. Information We Collect

We may collect the following categories of information:

4.1 Information You Provide Directly

When you register or use our Services, you may provide:

· Name, username, or nickname

· Email address

· Phone number

· Profile information (e.g., avatar, preferences)

· Communications with us

4.2 Account and Authentication Information

· Login credentials

· Third-party login information (e.g., external account identifiers)

4.3 Device and Technical Information

· Device type and model

· Operating system and version

· IP address

· Device identifiers (where permitted)

· Network information

4.4 Usage Information

· Pages visited

· Features used

· Time spent

· Interaction data

4.5 Location Information

We may collect general location information (e.g., country or region) based on IP address.

5. How We Use Your Information

We use your personal information for the following purposes:

5.1 Providing Services

· Account creation and management

· Delivering core functionality

· Customer support

5.2 Improving Services

· Analysing usage patterns

· Fixing bugs and improving performance

· Developing new features

5.3 Security and Fraud Prevention

· Detecting suspicious activity

· Preventing unauthorised access

5.4 Communications

· Sending service-related notices

· Responding to inquiries

5.5 Marketing (where permitted)

· Providing relevant promotions

· Improving advertising effectiveness

You may opt out of marketing communications at any time.

6. Cookies and Tracking Technologies

We use cookies and similar technologies to:

· Authenticate users

· Remember preferences

· Improve performance

· Analyse usage

· Deliver targeted advertising

6.1 Types of Cookies

· Essential cookies

· Performance cookies

· Functional cookies

· Advertising cookies

You may disable cookies via browser or device settings; however, this may affect functionality.

7. Sharing and Disclosure of Information

We do not sell your personal information. We may share it in the following circumstances:

7.1 Service Providers

We may share information with trusted third-party providers who assist in:

· Hosting

· Analytics

· Customer support

These parties are contractually required to protect your data.

7.2 Business Transfers

In the event of:

· Merger

· Acquisition

· Asset sale

Your information may be transferred. You will be notified where required.

7.3 Legal Compliance

We may disclose information if required to:

· Comply with legal obligations

· Respond to lawful requests

· Protect rights or safety

7.4 Third-Party Services

If you interact with third-party services:

· They may collect your information

· Their privacy policies apply

8. International Data Transfers

Your information may be stored or processed outside New Zealand.

Where this occurs, we take reasonable steps to ensure that:

· The recipient is subject to privacy protections comparable to NZ law, or

· Appropriate safeguards are in place

9. Data Retention

We retain personal information only for as long as necessary to:

· Provide Services

· Comply with legal obligations

· Resolve disputes

After this period, data is:

· Deleted, or

· Anonymised

10. Data Security

We implement reasonable safeguards, including:

· Encryption (HTTPS, secure storage)

· Access controls

· Monitoring systems

Despite these measures, no system is completely secure.

11. Your Rights

Under the Privacy Act 2020, you have the right to:

· Access your personal information

· Request correction

· Withdraw consent (where applicable)

Requests can be made via our contact details below.

12. Children’s Privacy

We do not knowingly collect personal information from children without parental consent.

If such data is identified, we will take steps to remove it.

13. Sensitive Information

Sensitive data (e.g., financial or identity information) is handled with enhanced safeguards.

You should carefully consider before providing such information.

14. Advertising and Marketing

We may use your information to:

· Personalise advertising

· Measure campaign effectiveness

You can opt out of marketing communications.

15. Communications

We may send:

· Service-related notices (mandatory)

· Marketing communications (optional)

16. Third-Party Links

Our Services may contain links to external platforms.

We are not responsible for their privacy practices.

17. Policy Scope

This Policy applies to all Services unless a separate policy applies.

It does not cover third-party services.

18. Changes to This Policy

We may update this Policy from time to time.

Where changes are significant, we will notify you.

Continued use constitutes acceptance.

19. Governing Law

This Policy is governed by the laws of New Zealand.

Disputes shall be resolved in New Zealand courts.

20. Contact Information

For questions or requests:

98 Billiards Entertainment Limited
Email: customer@98billiards.com