Last updated: 30/11/2024

Welcome to SATARANJI AFRICA!

This Privacy Policy (“Policy“) outlines how SATARANJI AFRICA collects, uses, protects, and discloses personal information obtained from anyone who uses our Services (“Users“), anyone who creates an account on the SATARANJI AFRICA website or any related content, features, mobile and web applications and other services (collectively the “Services“) which are brought to you by SATARANJI AFRICA, LLC and its affiliate companies.

This Policy addresses requirements in the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA“), as well as any other applicable international, national, and state requirements related to data collection, usage practices, and disclosures.

Please read this Policy closely. By using the Services, you agree to the handling of your information in accordance with this Policy. If you provide us with your information (directly or indirectly through our service providers) we will treat your information according to this Policy. If we need to use your Personal Information for any other purpose, other than as disclosed herein, we will update this Policy or ask for your previous consent, if necessary.

Summary of Key Points

We encourage you to read this entire Policy and our Terms of Service, but here are some key points that may be of your interest:

• 
  Personal Information (“PI“) means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
• 
  During registration, we may ask you to provide an email address, a username and if registration with a telephone number is available in your country, we will ask you to provide a telephone number.
• 
  We will never ask you to provide us with sensitive PI.
• 
  Paying Users are asked for payment information when they purchase anything from our Services. Please see Section “Information Collection“ for more information about how we safeguard payment information.
• 
  Because the security of your PI is important to us, we only ask for PI where it serves a business purpose and try to limit the collection of PI to only what is necessary to accomplish those purposes. We also use commercially reasonable physical, technical, and administrative security measures designed to safeguard all information collected by the Services.

Table of Contents

1. 
   Definitions
2. 
   Children’s Privacy
3. 
   Information Collection
4. 
   How We Use Information
5. 
   When We Disclose Information to Third Parties
6. 
   How to Exercise your Right to Access, Change or Correct your Information
7. 
   How to Exercise your Rights to Cancel and Delete your Account and How to Request Reactivation
8. 
   California Privacy Rights Act (CPRA)
9. 
   Additional Information regarding Personal Data processed subject to the General Data Protection Regulation (GDPR)
10. 
    Other Region and State-Specific Terms
11. 
    Links to Other Services
12. 
    Location of Information Processing
13. 
    Security
14. 
    Changes to Our Privacy Policy
15. 
    Contact Us
16. 
    Chess Play & Learn (Arcade Version)

Definitions

GDPR

GDPR collectively refers to the European Union (“EU“) and the United Kingdom (“UK“) General Data Protection Regulations.

Personal Data

Personal Data, as that term is defined in the GDPR, means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal Data and Personal Information will be used as synonyms for the purposes of this Policy.

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit). Usage Data may include pseudonymous data where applicable.

Cookies

Cookies and/ or similar technologies (collectively referred to as “Cookies“): are small pieces of data stored on your device (computer or mobile device).

Data Controller

Data Controller: means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any PI is, or is to be, processed. For the purpose of this Policy, we are a Data Controller of your Personal Data.

Data Processors

Data Processors: means any natural or legal person who processes the data on behalf of the Data Controller and follow their instructions, normally it refers to our service providers. We use the services of various Data Processors in order to process your data more effectively.

Data Subject

Data Subject is any living individual whose Personal Data we process.

Children’s Privacy

SATARANJI AFRICA is not targeted towards minors, meaning a person under the minimum age required to consent to the processing of their personal information as determined by applicable laws in their state or country of residence. Our platform at ChessKid.com is targeted towards minors.

Information Collection

There are two general categories of information that we collect.

Information Users Provide to Us

As more fully set forth below, we and our third-party service providers collect information that Users provide when using the Services, including when Users create an Account, sign up for Services, or contact us with a question, comment, or request.

To register an Account, Users may be asked to provide a username, an email address, and/or telephone number (which may be optional if you choose to register with an email).

We also allow Users to register an Account by connecting with an external third-party service such as Google, Apple, or Facebook. If you choose this way of registration, we may receive your PI from these third parties including but not limited to your name, email address, and contacts.

Users are also able to complete their profile with additional information which is optional such as: first and last name, location, country, language, content language, timezone, OTB rating, status, profile picture and any other information the User chooses to share in the “About me“ section of the profile. The flag of the country you choose will appear on your profile.

Keep in mind that certain information from your profile is public and therefore can be accessed by any User, and even by people outside SATARANJI AFRICA. By including information in your profile, you understand that the information that is public can be used by any person or entity for their own purposes.

There is also other information provided that depends on the type of Account. For example:

Payment information such as credit or debit card information and billing address is collected from Users who purchase a subscription, including those who gift a paid Account to others, unless Users are purchasing through iTunes, PayPal, or other similar mechanisms with which we integrate. For your security, we do not store your credit card number in our databases but we and our payment service providers may retain only the first six digits and/or last four digits to identify your Account and respond to your requests and questions and to process the payment.

In addition, Users can provide us with information through separate sections of the Services. These sections, accessible via the Menu or Settings link on the Services, allow Users to administer their Accounts, including when they provide testimonials, seek customer support, or submit comments or questions.

If you submit any information relating to other people in connection with the Services, you represent that you have the authority to do so and permit us to use the information in accordance with this Policy.

When you contact us directly by any means we will collect your email address, name and any information you provide.

When we embed or display content from YouTube on our Services, we are using YouTube API Services. In these cases, we collect, store, and use User information related to YouTube API services. By accessing YouTube content on our Services, you agree to be bound by YouTube terms of service, found at https://www.youtube.com/static?template=terms.

If you want to revoke this access to your data, you can do so via the Google security settings page at https://security.google.com/settings/security/permissions.

YouTube is a service provided by Google. For more information about how Google collects and uses data, please refer to the Google Privacy Policy at http://www.google.com/policies/privacy.

Information We Collect from Users

We and our third-party service providers collect PI directly from Users of the Services in the form of the actions they take and activities they complete when using the Services. For example, from all Users, we may collect information about patterns of usage and order history.

We and our third-party service providers also use a variety of technologies, such as Cookies, to automatically collect certain technical information from your computer or mobile device over time and across different websites.

We and our third-party service providers may use the information collected through these technical methods for several purposes, including delivering content, tracking and enhancing our Users’ experience with the Services, and delivering advertising to visitors of our Services when they visit other websites and applications. For example, when you return to the Services after logging in, Cookies help the Services recognize who you are without having to log back in. More information about the use of Cookies is set forth below.

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

PI

While using our Service, we may collect certain PI which may include but is not limited to:

• • 
    Required Information (username, email address, or telephone number, as applicable)
  • 
    Optional Information (first and last name, location, country, language, content language, timezone, OTB rating, status, profile picture and any other information the User chooses to share in the “About me“ section of the profile)
  • 
    Public available chess records from FIDE (Fédération Internationale des Échecs)
  • 
    We may use your PI to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you, we will ask for your previous consent, if that is required by the applicable legislation. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, by changing your notification settings in your profile or by contacting us.
  • 
    If you use our App for the Apple or Android platform, we may ask, with your permission, to collect your contact list information (including email addresses and phone numbers) to share with Apple or Google for the exclusive purpose of finding your friends and connections.
  • 
    If you participate in one of our chess competitions with prizes, you may be required to install software that monitors your activity on your computer or device. This software may log your device processes and tabs, record your device screen, access your webcam(s) and video, record your input and output audio, and track your mouse or cursor movement. This PI will be collected and disclosed to a third-party to conduct the competition, to prevent, detect and investigate violations of the competition’s rules and our Fair Play Policy as further described in Section 5 (When We Disclose Information to Third Parties).
  • 
    We also collect Usage Data and Cookies Data, as described below in separate sections.

Usage Data

We may also collect information that your browser sends to us whenever you visit our Service or when you access the Service through a mobile device (“Usage Data“).

This Usage Data may include information such as your Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, your country, your chess statistics and other diagnostic data.

When you access the Service by or through a mobile device, this Usage Data may include information such as your browser type, operating system, device type, the page served, your IP

address, how you got to our Website, the time and length of your visit, your language preferences, your approximate geolocation, and the websites you visited prior to visiting the Services. When you download and use one of our Apps, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.

Cookies Data

We use Cookies to provide you with the Services, to track the activity on our Service and to hold certain information. We use the following types of Cookies to recognize your device and to provide and improve our Services:

Essential Cookies

These Cookies are essential to provide you with services available through the Services and enable you to use some of its features. For example, they allow you to log in to secure areas of our Services and help the content of pages you request load quickly. Without these Cookies, the Services that you have asked for cannot be provided, and we only use these Cookies to provide you with those Services. You may not disable these types of Cookies.

Functionality Cookies

These Cookies allow us to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details, and remembering the changes you make to other parts of Services which you can customize. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to reenter your preferences every time you visit our Services.

Analytics and Performance Cookies

These Cookies are used to collect information about traffic to our Services and how Users use the Services. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information, and to monitor the level of activity on our Services.

Social Media Cookies

These Cookies are used when you share information using a social media sharing button or “like“ button on our Services or engage with our content on or through a social networking website such as Facebook, Twitter, or Google+ and also if you choose to sign up using your social media account. These cookies are also placed on your browser if you access to a section of our Services that provides you with embedded videos from Youtube, Twitch or other third-party websites. Some of these cookies may be considered essential if you log in using your social media account.

Targeting Cookies

Targeting Cookies are used to serve you with advertisements that may be relevant to you and your interests. Third parties might use information gathered by cookies and/or web beacons for the purpose of online behavioral advertising. The types of information that is gathered by third party cookies and/or web beacons as well as the purpose(s) for which this information is used, are set out in the privacy policy of said third parties which we encourage you to review.

SATARANJI AFRICA declines all and any liability for any third party cookies or web beacons deployed by third parties for whatever purpose.

Google, as a third-party vendor, uses cookies to serve ads on our Service. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet. You may opt-out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences.

Depending on your country of residence, you may allow or reject the use of non-essential Cookies when using our Services by changing your Cookie preferences here. However, please note that if you reject or block certain categories of Cookies from the Services, the Services may not function as intended. For example, you will not be able to remain logged into your Account, and therefore you would have to log in during each page transition.

You may also opt-out of the use of your PI for interest based advertising by visiting Your ad choices, Your online choices, Transparent advertising, LiveRamp opt out or NAI Consumer opt out.

How We Use Information

We and our third-party service providers may use the information collected from Users as follows:

• • 
    To permit you to register and use the Services, including, for example, to send you communications about your Account, or to allow you to provide feedback through the Support or Contact Us Sections. (Lawful Basis: to comply with our legal obligations and performance of our contract with you)
  • 
    To complete and fulfill your purchase, such as to process your payments, communicate with you regarding your purchase, and provide you with related customer service. (Lawful Basis: performance of our contract with you, to comply with our legal obligations and necessary for our legitimate interests)
  • 
    To respond to your inquiries and fulfill your requests, retrieve your password, or provide technical support. (Lawful Basis: performance of our contract with you, to comply with our legal obligations and necessary for our legitimate interests)
  • 
    To provide you with information, newsletters, marketing communications, publications and other communication via various mediums to keep you informed (Lawful Basis: your consent, performance of our contract with you and necessary for our legitimate interests)
  • 
    To deliver our advertising to you based on your visits to the Services. (Lawful Basis: your consent and necessary for our legitimate interests)
  • 
    To measure the effectiveness of our advertising. (Lawful Basis: performance of our contract with you and necessary for our legitimate interests)
  • 
    To allow us to assess and improve the Services, its educational content, and other services we provide (for example, to improve our content and User experience); to research, evaluate, and improve the educational efficacy of the Services; and to inform our understanding of the Services’ User base. (Lawful Basis: performance of our contract with you and necessary for our legitimate interests)
  • 
    To verify your identity or conduct appropriate checks for fraud prevention and detection (Lawful Basis: to comply with our legal obligations and necessary for our legitimate interests)
  • 
    To customize, adapt, and personalize Users’ viewing and content-consumption experience. (Lawful Basis: performance of our contract with you, your consent and necessary for our legitimate interests)
  • 
    To maintain and analyze the functioning of the Services. (Lawful Basis: necessary for our legitimate interests)
  • 
    To manage and conduct our business (Lawful Basis: performance of our contract with you and necessary for our legitimate interests)
  • 
    As we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and governmental authorities, including authorities outside your country of residence; (d) to detect violations of and enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates, including the security of the Services; (f) to protect our rights, privacy, safety, or property, or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain (collectively, (a)-(g) are Other Uses and Disclosures). (Lawful Basis: to comply with our legal obligations and necessary for our legitimate interests)
  • 
    To send you push notifications, SMS, alerts and or other types of notifications on your mobile device. You may choose to stop receiving push notifications at any time by changing the settings on your mobile device. If you provide us with your mobile phone number, we may send you SMS text messages about your account with your previous consent if required by law. Please note that your carrier may charge you for the text messages you receive. To permanently stop receiving SMS text messages from us (if you are located in the U.S. or Canada) text STOP, CANCEL, or UNSUBSCRIBE in reply to any SMS text message sent by us. (Lawful Basis: performance of our contract with you, to comply with our legal obligations and necessary for our legitimate interests)
  • 
    To research and develop new products and services (Lawful Basis: performance of our contract with you and necessary for our legitimate interests)
  • 
    To publish your name in case you are the winner of a contest, sweepstake, tournament or events in general. (Lawful Basis: performance of our contract with you, your consent and necessary for our legitimate interests)
  • 
    For administrative purposes (Lawful Basis: performance of our contract with you and necessary for our legitimate interests)
  • 
    To conduct our competitive events and to prevent, detect and investigate violations of our Fair Play Policy, Competitive Events Policy and the rules of any event organized by us. (Lawful Basis: performance of our contract with you, to comply with our legal obligations, your consent and necessary for our legitimate interests)
  • 
    To carry out any other purpose described to you at the time the information was collected.

When We Disclose Information to Third Parties

Information collected from Users will not be disclosed except for the following purposes, which include our operations purposes:

• • 
    To service providers such as payment processors, financial institutions, technological, analytical, marketing, advertising service providers and partners and third party professional advisors (i.e., auditors, law firms, etc.), provided that, the service providers agree to keep the information confidential.
  • 
    To our affiliates and business partners and their employees for business purposes, when necessary for the purpose of the provision of our services or when such affiliates provide services to us.
  • 
    As needed to conduct our competitive events and to prevent, detect and investigate violations of our Fair Play Policy, Competitive Events Policy and the rules of any competitive event organized by us.
  • 
    As we believe to be necessary or appropriate as set forth above in Other Uses and Disclosures.
  • 
    With government bodies and law enforcement or where we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. If required or permitted to do so under the law, and if deemed necessary or warranted, we may provide notice to Users prior to the disclosure.
  • 
    Subject to confidentiality agreements, the terms of this Policy, and applicable law, information may be disclosed to service providers, advisers, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we or any of our affiliates are acquired by or merged with another company, or we sell, liquidate, transfer, or license all or a portion of our assets in bankruptcy or otherwise. This means that if some or all our assets are acquired or otherwise transferred or licensed, including in bankruptcy, that such acquirer shall be subject to the same commitments stated under this Policy.
  • 
    We may use third-party advertising networks and other affiliates in association with cookies, pixel tags, IFrames or similar technologies to: (1) deliver interest-based

advertising to those Users, including our advertising, when those Users visit third-party websites; and (2) provide us with statistics about the effectiveness of our advertising on third-party websites. These third-party advertising networks may use this cookie information in accordance with their own privacy policies.

• • 
    To provide you with relevant content and personalized advertisements, we may share information that we collect from you, such as your phone number, email address (in hashed form), IP address or information about your browser or operating system, with advertising service providers and its affiliates, which may in turn link demographic or interest-based information to you. If you are in the EU and wish to opt-out of this use, you can go here and reject the cookies categorized under advertising.
  • 
    To a third-party that uses or supports referral links to our Services only if you click on a referral link.
  • 
    Any third-party where such disclosure is required in order to enforce or apply our Terms of Service or other relevant agreements.
  • 
    Any third-party if necessary to protect the rights, property, integrity or security of our company, our customers, or others (including, without limitation, you).

For service efficiency purposes, some of these affiliates and third parties are located in territories outside the EU/EEA, and from time to time we may transfer your personal data to a third country not being approved by the European Commission as a safe country for such transfer (adequacy decision). If you are a EU/EEA resident and whenever applicable we will use the Standard Contractual Clauses to ensure an equivalent level of protection as granted within the EU/EEA or other lawful grounds for carrying out said transfer.

How to Exercise your Right to Access, Change or Correct your Information

Any User can review or change the information they provided when they registered for the Services by updating the information on their Account profile or by contacting Support. You also can exercise your right of access by requesting it on the “My data“ Section of our Services. In addition, Users may contact us at any time as described in Section “Contact Us“ below, to request that we provide for their review any PI they have provided, or to cease collecting PI from the User.

When we change any PI at your request, we will make reasonable efforts to make the changes in our then-active databases as soon as reasonably practicable and always within the applicable legal term. Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules.

How to Exercise your Rights to Cancel and Delete your Account and How to Request Reactivation

Users may cancel their Accounts at any time by using the “Manage Account“ section in the settings or by contacting Support.

Please bear in mind that after an Account is canceled, the PI and other Account information is not deleted permanently. We store the User information to allow the User to reopen their

Account at any time. However, we provide no guarantee, and shall have no liability or obligation to ensure, that all Account Information and Services-related progress will be available or accessible or all learning or personalization features will be able to be recovered or resumed.

Upon Account cancellation or execution of a deletion request (as explained below), anonymized User information may nonetheless persist internally in our backup, archive files or similar databases, and may still be used anonymized, for our internal support, administrative, and record-keeping purposes including, but not limited to, allowing us to improve the Services and other services we provide through research, evaluation, and analytics as permissible by applicable law and for other purposes specifically outlined in this Policy. We may also keep certain information in backup or archive records if required by law or if it is relevant to preventing fraud or future violations of our policies or for legitimate business purposes when permitted by applicable law. All retained data will continue to be subject to our Policy in effect at that time

Following cancellation of an Account, to reactivate your Account and potentially recover previous information and resume where the relevant User left off you will need to request it to Support using the email address associated with your Account.

If you want to permanently delete your PI you may, if the functionality’s present, request it manually by clicking on “Delete“ on the “My Data“ section of the Services or by requesting deletion to Support. In this case, we will delete your PI, anonymize the information that will remain public such as games statistics, posts and comments, and block your email address and social media accounts from being used on SATARANJI AFRICA in the future.

If you want your posts and public comments to be removed, you must delete them separately before requesting deletion. After you delete your personal data, SATARANJI AFRICA Support Staff will have no means to verify your identity and will not remove these posts for you.

Any data deletion requests will be executed within the term provided by the applicable law.

Please keep in mind that a request to delete PI may lead to cancellation of your Account or the inability to use certain Services, and if any other Account type is linked to a Member Account, a request to delete PI in one of the Accounts may be reflected in your other Account.

California Privacy Rights (CPRA)

This Section supplements the information contained in our Policy and applies solely to Users who reside in the State of California. We adopt this notice to comply with the CCPA. Any terms used in this Section have the same meaning as defined in the CCPA. Please note that we may claim legal exemptions for certain types of PI and certain of our Services from all or certain parts of the CCPA.

The CCPA provides California residents with specific rights regarding their PI. This section describes your CCPA rights and explains how to exercise those rights. In this section “you“ or “your“ refers to California residents. Under the CCPA, we are required to disclose the categories of sources from whom we collect PI, and the third parties with whom we share it — which we

already have explained above in Section “Information Collection“, Section “How We Use Information“, and Section “When We Disclose Information to Third Parties“.

We do not have actual knowledge that we “sell” or “share” (as those terms are defined under the CCPA and used throughout this section) personal information of residents under 16 years of age. However, we have, in the preceding 12 months, sold and/or shared the phone numbers, email addresses (in hashed form), IP addresses or browser or operating system information of California residents to advertising service providers and their affiliates for the business purpose of providing personalized content and advertising.

Only you as a California resident or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your PI.

The verifiable consumer request must:

• 
  Provide sufficient information that allows us to reasonably verify you are the person about whom we collected PI or an authorized representative. We will verify your request by asking you to provide information related to your interactions with us. We will not otherwise ask for PI from you that we would not otherwise maintain as part of us providing our Services.
• 
  Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• 
  We cannot respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. Making a verifiable consumer request does not require you to create an Account with us. We will only use PI provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

To exercise your rights please follow the steps described below, or request it to us by contacting Support or by following the steps described below:

• Right to access PI. You may be entitled to receive information regarding the categories of PI we collected, the sources from which we collected PI, the purposes for which we collected and shared PI, the categories of PI that we share and the categories of third parties to whom the PI was shared with, and the categories of PI that we disclosed for a business purpose in the last 12 months. You can exercise this right by requesting it on the “My data“ Section of our Services.
• Right to data portability. You may be entitled to receive a copy of your electronic PI in a readily usable format so you can transmit this data to another organization. You may only make a verifiable consumer request for access or data portability twice within a 12- month period. You can exercise this right by requesting it on the “My data“ Section of our Services.
• Right to Correct. You have the right to request that we correct inaccurate PI that we maintain about you. You are also able to correct any inaccurate PI manually by accessing your profile on the Settings sections of the Services.
• Right to deletion. You may be entitled to request that we delete the PI that we have collected from you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws. Please note, however, that we may need or be required to keep such information for our legitimate business purposes or to comply with applicable law. To know how to exercise your right to deletion, please refer to the section titled: “Account Cancellation and Reactivation; Data Deletion“ from this Policy.
• Right to opt-out of certain sharing with third parties. If you are a California resident, you have the right to request us to not disclose your PI to third parties for monetary or other valuable consideration or also known as the right to “Not Sell or Share My Personal Information”

You can exercise such right to opt-out by submitting the following form.

“Do Not Track“ Signals

We do not respond to Do Not Track (“DNT“) signals received from web browsers. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. If you enable DNT functionality on any device, some of the Services, including paid Services or SATARANJI AFRICA subscriptions, may become unstable.

Information We Collect and Share

We have collected the following categories of PI from or about consumers within the last 12 months:

Identifiers

• 
  A real name or alias
• 
  Internet Protocol address(es)
• 
  Email address
• 
  Account name (username), or other similar identifier
• 
  Mobile push tokens
• 
  Specific third-party identifiers relating to chess services (e.g., USCF or FIDE ID number) may be collected for some accounts
• 
  Information you provide us
• 
  Information we collect from you automatically
• 
  3rd Party Service Provider

Geolocation Data

• 
  IP address data
• 
  Information we collect from you automatically

Internet or other similar network activity

• 
  Browsing history; information on a User’s interaction with the Services; information regarding your operating system and device
• 
  Information we collect from you automatically
• 
  3rd Party Service Provider

For additional information regarding the PI we collect and have collected in the 12 months preceding the effective date of our Policy, the heading above styled “Types of Data Collected“ under Section 3.B. (Information We Collect from Users).“

Business and Commercial Purposes for Which We Use PI

We may use or disclose the PI we collect from each of the Categories of PI (described in the table above) for one or more of the following purposes:

See Section 3 above (How We Use Information).

Categories of PI We Share:

We may share your PI by disclosing it to a third party for a business purpose described below. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the PI confidential, and prohibit using the disclosed information for any purpose except performing the contract.

In the preceding 12 months, we have also disclosed the following categories of PI for one or more business purposes:

We share Category A, B, and C Personal Information with our Affiliates, partners, parent/subsidiary organizations, service providers, and government entities and advertising networks.

Our Retention of PI

We retain PI for as long as necessary to provide the Services and fulfill the transactions you have requested, or for other business purposes, to comply with our legal obligations, resolving disputes, and enforcing our agreements. We decide how long we need PI on a case-by-case basis. We may consider the following factors when making retention decisions:

• 
  Whether we need to keep some of your PI to maintain your Account;
• 
  Whether we are required by law to keep some types of PI for certain periods of time to comply with our legal obligations; and
• 
  Whether we need some of your PI for other business purposes, such as to prevent harm and ensure safety and security of our Sites; investigate possible violations of our terms and conditions of use; or protect ourselves.

Non-Discrimination

We fully support your privacy rights and will not discriminate against you for exercising any of your CCPA rights.

Notice of Financial Incentives

We may offer special incentives to Users who enroll in certain promotions. The availability of these promotions to you at any given time will vary. If we offer such programs, we may ask for your PI as a prerequisite to your participation in the promotion.

Additional Information regarding Personal Data Processed subject to the General Data Protection Regulation (GDPR)

If you are located in the EEA or the UK, our legal basis for collecting and using the Personal Data described in this Policy depends on the Personal Data we collect and the specific context in which we collect it.

The purpose of this section of this Policy is to explain how you may exercise certain of your rights under applicable data privacy laws related to that information. This policy identifies our legal representative and Data Protection Office in the EEA and UK and provides you with the information that you may need to contact them. We (SATARANJI AFRICA, LLC) are the data controller for the processing of your information. Please see Section “Contact Us“ below for our contact details.

Our legal representative Contact: Sataranji Africa, Legal

Postal Address: 50533-00100

Nairobi, Kenya

Retention of Data

We will retain your Personal Data only for as long as necessary for the purposes set out in this Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies, or until you instruct us to do otherwise in a fashion consistent with your rights (and our obligations) under the GDPR.

Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — servers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we are a United States based provider. Therefore, we operate our Services, collect and process your Personal Data from the United States.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your Personal Data. If we onward transfer your Personal Data outside the EEA or the UK, we rely on the European Commission’s standard contractual clauses and the UK Information Commissioner’s equivalent transfer mechanism, as relevant. This is unless the transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals’ Personal Data.

Your Data Protection Rights Under the GDPR

If you are located in the EEA or the UK, then you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed on what Personal Data we hold about you or if you want it to be removed from our systems, please contact us at the contact information provided in Section “Contact Us“, below.

You can edit your Account information at any time. In certain circumstances, you have the following data protection rights:

• The right to access and to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format. You can exercise this right by requesting it on the “My data“ Section of our Services
• The right to update, correct and rectify your personal data. You are also able to update, correct or rectify any inaccurate Personal Data manually by accessing your profile on the Settings sections of the Services.
• The right to delete the information we have on you. To know how to exercise your right to deletion, please refer to the section titled: “Account Cancellation and Reactivation; Data Deletion“ from this Policy.
• The right to object. You have the right to object to our processing of your Personal Data. You can do it by contacting us via the contact information provided in Section “Contact Us“.
• The right to object to marketing. You can object to marketing at any time by opting-out using the unsubscribe/ opt-out function displayed in our communications to you or by managing your preferences on the Notifications section from the Settings.
• The right of restriction. You have the right to request that we restrict the processing of your Personal Data if this is applicable by contacting us via the contact information provided in Section “Contact Us“.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your Personal Data by contacting us via the contact information provided in Section “Contact Us“.
• Manage your cookie consent. Depending on your country of residence, you may allow or reject the use of non-essential Cookies when using our Services by changing your Cookie preferences here.

If you are unable to perform these actions yourself or if you have any complaints about how we process your Personal Data please contact us via the contact information provided in Section “Contact Us“ to assist you.

Please note that we may ask you to verify your identity before responding to such requests. Some of these rights only apply in certain circumstances and in many cases, are limited by law. For example, where fulfilling your request will adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interest reasons or where we are required by law to retain your Personal Data. We will respond to your requests to exercise these rights as required by applicable law.

You also have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. However, we invite you to contact us with any concern, as we would be happy to try to resolve it directly. For more information, please contact (a) your local data protection authority in the EEA country in which you reside or work, or where you think an infringement of data protection laws occurred or (b) the UK Information Commissioner’s Office, as applicable to you.

Appointment of the Data Protection Officer

Sataranji Africa, Data Protection Officer is our GDPR Data Protection Officer. The Data Protection Officer may be contacted via 50533-00100 Nairobi, Kenya.

Other Region and State-Specific Terms

United States

1. Colorado Residents

Scope. This section applies only to Colorado residents. It describes how we collect, use, and share Personal Data of Colorado residents in our capacity as a business under the Colorado Privacy Rights Act (“CPA“) and your rights with respect to that Personal Data. For purposes of this section, the term “Personal Data“ has the meaning given in the CPA but does not include information exempted from the scope of the CPA. Please note that we may claim legal exemptions for certain types of Personal Data and certain of our Services from all or certain parts of the CPA.

Your Colorado privacy rights. As a Colorado resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• • Access. You may request confirmation whether we are processing your Personal Data and access to such Personal Data by requesting it on the “My data“ Section of our Services.
  • Correction. You can edit and correct your Personal Data at any time by by accessing your profile on the Settings sections of the Services.
  • Deletion. You may have the right, under certain circumstances, to request that we delete the Personal Data you have provided to us. To know how to exercise your right to deletion, please refer to the section titled: “Account Cancellation and Reactivation; Data Deletion“ from this Policy or contact us at the contact information provided in Section “Contact Us“, below.
  • Data portability. You may be entitled to receive a copy of your electronic Personal Data in a readily usable format. You can exercise this right by requesting it on the “My data“ Section of our Services.
  • Opt-out of tracking for targeted advertising purposes. If available in your residence or if mandated by law, you may be able to submit requests to opt-out of tracking for targeted advertising purposes by clicking on the following link.
  • Opt-out of profiling. You have the right to opt-out of the automated processing of your Personal Data to evaluate, analyze, or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements, to the extent this results in decisions that produce legal or similarly significant effects. However, we do not perform this type of profiling.
  • Sensitive Personal Data. We will not process your sensitive Personal Data without your consent.
  • Non-discrimination. You have the right to be free from discrimination related to your exercise of any of your Colorado privacy rights.

Authentication. In order to protect your Personal Data from unauthorized access or deletion, we may require you to verify your credentials before you can submit a rights request. If you do not have an Account with us, or if we suspect that your Account has been accessed without your authorization, we may ask you to provide additional PI for verification. If we are subsequently unable to confirm your identity, we may refuse your rights request.

Connecticut Residents

Scope. This section applies only to Connecticut residents. It describes how we collect, use, and share Personal Data of Connecticut residents in our capacity as a business under the Connecticut Data Privacy Act (“CDPA“) and your rights with respect to that Personal Data. For purposes of this section, the term “Personal Data“ has the meaning given in the CDPA but does not include information exempted from the scope of the CDPA. Please note that we may claim legal exemptions for certain types of Personal Data and certain of our Services from all or certain parts of the CDPA.

Your Connecticut privacy rights. As a Connecticut resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• • Access. You may request a copy of the Personal Data by requesting it on the “My data“ Section of our Services.
  • Correction. You can edit and correct your Personal Data at any time by by accessing your profile on the Settings sections of the Services.
  • Deletion. You may have the right, under certain circumstances, to request that we delete the Personal Data you have provided to us. To know how to exercise your right to deletion, please refer to the section titled: “Account Cancellation and Reactivation; Data Deletion“ from this Policy or contact us at the contact information provided in Section “Contact Us“, below..
  • Data portability. You may be entitled to receive a copy of your electronic Personal Data in a readily usable format. You can exercise this right by requesting it on the “My data“ Section of our Services
  • Opt-out of tracking for targeted advertising purposes. If available in your residence or if mandated by law, you may be able to submit requests to opt-out of tracking for targeted advertising purposes by clicking on the following link.
  • Opt-out of profiling. You have the right to opt-out of the automated processing of your Personal Data to evaluate, analyze, or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements, to the extent this results in decisions that produce legal or similarly significant effects. However, we do not perform this type of profiling.
  • Sensitive Personal Data. We will not process your sensitive Personal Data without your consent.
  • Non-discrimination. You have the right to be free from discrimination related to your exercise of any of your Connecticut privacy rights.

Authentication. In order to protect your Personal Data from unauthorized access or deletion, we may require you to verify your credentials before you can submit a rights request. If you do not have an account with us, or if we suspect that your account has been accessed without your authorization, we may ask you to provide additional Personal Data for verification. If we are subsequently unable to confirm your identity, we may refuse your rights request.

Virginia Residents

Scope. This section applies only to Virginia residents. It describes how we collect, use, and share Personal Data of Virginia residents in our capacity as a business under the Virginia Consumer Data Protection Act (“VCDPA“) and your rights with respect to that Personal Data. For purposes of this section, the term “Personal Data“ has the meaning given in the VCDPA but does not include information exempted from the scope of the VCDPA. Please note that we may claim legal exemptions for certain types of PI and certain of our Services from all or certain parts of the VCDPA.

Your Virginia privacy rights. As a Virginia resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• • Know. You have a right to know whether we are processing your Personal Data.
  • Access. You may request a copy of the Personal Data by requesting it on the “My data“ Section of our Services.
  • Correction. You can edit and correct your Personal Data at any time by by accessing your profile on the Settings sections of the Services.
  • Deletion. You may have the right, under certain circumstances, to request that we delete the Personal Data you have provided to us. To know how to exercise your right to deletion, please refer to the section titled: “Account Cancellation and Reactivation; Data Deletion“ from this Policy or contact us at the contact information provided in Section “Contact Us“, below.
  • Opt-out of tracking for targeted advertising purposes. If available in your residence or if mandated by law, you may be able to submit requests to opt-out of tracking for targeted advertising purposes by clicking on the following link.
  • Opt-out of profiling. You have the right to opt-out of the automated processing of your Personal Data to evaluate, analyze, or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements, to the extent this results in decisions that produce legal or similarly significant effects. However, we do not perform this type of profiling.
  • Sensitive Personal Data. We will not process your sensitive Personal Data without your consent.
  • Non-discrimination. You have the right to be free from discrimination related to your exercise of any of your Virginia privacy rights.

Authentication. In order to protect your Personal Data from unauthorized access or deletion, we may require you to verify your credentials before you can submit a rights request. If you do not have an account with us, or if we suspect that your account has been accessed without your authorization, we may ask you to provide additional Personal Data for verification. If we are subsequently unable to confirm your identity, we may refuse your rights request.

Australia

If you are a resident of Australia, you may have the following rights and choices:

Update your privacy settings. You may update your privacy settings by visiting your account settings

Manage marketing communications from us. To update your marketing communication preferences, you can contact us at the contact information provided in Section “Contact Us“, below.

Access, Correction or Deletion. You may request to access, to correct or to delete your PI. You can edit and correct your PI at any time by changing it directly in our Services. To make a request for access you may do it by requesting it on the “My data“ Section of our Services. To know how to exercise your right to deletion, please refer to the section titled: “Account

Cancellation and Reactivation; Data Deletion“ from this Policy or contact us at the contact information provided in Section “Contact Us“, below.

Objection and Restriction. You may object to our processing of your PI, including for marketing purposes, or ask us to restrict processing of your PI. To object to data processing or request a restriction, contact us at the contact information provided in Section “Contact Us“, below. If you request that we stop processing some or all of your PI or you withdraw (where applicable) your consent for our use or disclosure of your PI for purposes set out in this privacy notice, we might not be able to provide you all of the Services and customer support offered to our users and authorized under this Notice.

Brazil

Legal Basis of Processing

We use your PI only as permitted by law. Applicable Brazil data protection law requires us to have a “legal basis“ for each purpose for which we collect your PI. Our legal basis for collecting and using the PI described in this Privacy Statement will depend on the type of PI and the specific context in which we collect it. However, we will normally process PI from you when:

• • 
    We have your consent to do so;
  • 
    We have a contract with you and it is necessary to process your PI to perform our contract with you, including to provide you with the benefits of our Services and operate our business;
  • 
    The processing is in our legitimate business interests, such as operating our businesses, improving and developing Services, communicating with you, marketing our offerings and services, and personalizing your experience, and to detect illegal activities; and/or
  • 
    To comply with legal requirements, including applicable laws and regulations.

Sharing with Credit Bureaus

Inapplicable.

If you are a resident of Brazil, you may have the following rights and choices:

Update your privacy settings. You may update your privacy settings by visiting your account settings

Manage marketing communications from us. To update your marketing communication preferences, you can change your notification preferences by going to the “Settings“ section on your account.

Access, Correction, Anonymization or Deletion. You may request to access, to correct, anonymize or to delete your PI. You can edit and correct your PI at any time by changing it directly in our Services. To make a request for access you may do it by requesting it on the “My data“ Section of our Services. To know how to exercise your right to deletion, please refer to the section titled: “Account Cancellation and Reactivation; Data Deletion“ from this Policy or contact us at the contact information provided in Section “Contact Us“, below.

Objection and Restriction. You may object to our processing of your PI or ask us to restrict processing of your PI. You may request objection, restriction and portability rights by contacting us at the contact information provided in Section “Contact Us“, below.

Portability. You may request portability of your PI.

Withdraw Consent. If we have collected and processed your PI with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your PI conducted in reliance on lawful processing grounds other than consent.

File a complaint. You have the right to file a complaint with a supervisory authority about our collection and processing of your PI.

Canada

While we take steps to maintain protection of your PI, your PI may be disclosed in response to valid demands or requests from governments, regulators, courts, and law enforcement authorities in those other jurisdictions or countries.

If you are a resident of Canada, you may have the following rights and choices:

Update your privacy settings. You may update your privacy settings by visiting your account settings.

Manage marketing communications from us. To update your marketing communication preferences, you can contact us at the contact information provided in Section “Contact Us“, below. You may also click unsubscribe at the bottom of any marketing emails or messages.

Cookies and other tracking technologies. If available in your country or mandated by law, you may be able to opt-out of interest based advertising by using the following link or by visiting the Digital Advertising Alliance of Canada Opt-Out Page, NAI Opt-Out Page and the Choices Opt- Out Page.

Access, Correction or Deletion. You may make a request to access, to correct or to delete your PI (provided we no longer have a business need to retain your PI). You may request a copy of the PI or delete the PI in your Account by contacting us at the contact information provided in Section “Contact Us“, below. You can edit and correct your PI at any time by changing it directly in our Services. Even if you request for your PI to be deleted, certain aspects may be retained for us to: meet our legal or regulatory compliance (e.g., maintaining records of transactions you have made with us); exercise, establish, or defend legal claims; and to protect against fraudulent or abusive activity on Site or while using our Services.

Withdraw consent. You can withdraw your consent at any time to collection, use, and disclosure of your PI. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your PI conducted in reliance on lawful processing grounds other than consent.

File a complaint. You have the right to file a complaint with the applicable Privacy Commissioner about our collection and processing of your PI.

India

Where data of Indian individuals is involved, you agree that the “reasonable security practices and procedures“ under Section 43A’s Explanation (ii) of the Information Technology Act, 2000 means this Privacy Statement and such data security procedures that we may implement from time to time, and which we may, in our discretion, give you notice from time to time.

What you can do to manage your privacy

You have choices when it comes to managing the privacy of your PI.

Update your privacy settings. You may update your privacy settings by visiting your account settings

Manage marketing communications from us. To update your marketing communication preferences, you can contact us at the contact information provided in Section “Contact Us“, below.

Correct your PI. You can edit and correct your PI at any time by changing it directly in our Services.

Mexico

If you are a resident of Mexico, you may have the following choices and rights (known as “ARCO rights“):

You have choices when it comes to managing the privacy of your PI and exercising your ARCO rights. Please note that we are required to verify your request prior to exercising your rights.

After we have received a request, our response will indicate whether the request for access, rectification, cancellation or opposition is appropriate and, if so, the determination will be made within 15 business days from such date. The deadlines may be extended under the terms set out in the applicable laws.

Access. You have the right to know what personal data we have about you, what we use it for and the conditions of use we give to it. Electronic copies of your personal data will be provided if you exercise your right of access. You may request a copy of the Personal Data by requesting it on the “My data“ Section of our Services. When making a request, please provide a clear and precise description of the personal data you wish to access and any other information that facilitates the location of your data.

Rectification. You have the right to request the correction of your personal data if it is outdated, inaccurate, or incomplete (Rectification). You can edit and correct your Personal Data at any time by by accessing your profile on the Settings sections of the Services.

Deletion/Cancellation. You have the right to request that we remove your PI from our records or databases when you consider that it is not being used in accordance with the principles, duties,

and obligations provided for in the applicable laws. To know how to exercise your right to deletion, please refer to the section titled: “Account Cancellation and Reactivation; Data Deletion“ from this Policy or contact us at the contact information provided in Section “Contact Us“, below. When making a request, please provide a clear and precise description of the personal data you wish to delete/cancel or any other information that facilitates the location of your data.

Opposition/Rejection. You have the right to oppose the use of your personal data for specific purposes. You may request objection, restriction and portability rights by contacting us at the contact information provided in Section “Contact Us“, below. When making a request, please provide a clear and precise description of the personal data you wish to oppose, or any other information that facilitates the location of your data.

Update your privacy settings. You may update your privacy settings by visiting your account settings and, if available in your country or mandated by law, manage your cookies using the following link.

Manage marketing communications from us. To update your marketing communication preferences, you can contact us at the contact information provided in Section “Contact Us“, below.

How to limit the use and disclosure of your PI

If you are a resident of Mexico, you also have the right to limit the use or disclosure of your PI by contacting us at the contact information provided in Section “Contact Us“, below.

How to withdraw your consent

If you are a resident of Mexico, you also have the right to withdraw your consent for our processing of your PI by contacting us at the contact information provided in Section “Contact Us“, below.

Thailand

Legal Basis of Processing

We use your PI only as permitted by law. The Thai Personal Data Protection Act (“PDPA“) requires us to have a “legal basis“ for collecting your PI. Our legal basis for collecting and using the PI described in this Privacy Statement will depend on the type of PI and the specific context in which we collect it. However, we will normally process PI from you when:

• • 
    We have your consent to do so;
  • 
    We have a contract with you and it is necessary to process your PI to perform our contract with you, including to provide you with the benefits of our Services and operate our business;
  • 
    The processing is in our legitimate business interests, such as operating our businesses, improving and developing Services, communicating with you, marketing our offerings and services, and personalizing your experience, and to detect illegal activities; and/or
  • 
    To comply with legal requirements, including applicable laws and regulations. If you are a resident of Thailand, you may have the following rights and choices:

Update your privacy settings. You may update your privacy settings by visiting your account settings and, if available in your country or mandated by law, manage your cookies using the following link.

Manage marketing communications from us. To update your marketing communication preferences, you can change your notification preferences by going to the “Settings“ section of your Account.

Access, Correction, Anonymization or Deletion. You may request to access, to correct, or to delete your PI. You can edit and correct your PI at any time by changing it directly in our Services. To make a request for access you may do it by requesting it on the “My data“ Section of our Services. To know how to exercise your right to deletion, please refer to the section titled: “Account Cancellation and Reactivation; Data Deletion“ from this Policy or contact us at the contact information provided in Section “Contact Us“, below.

Objection and Restriction. You may object to our processing of your PI or ask us to restrict processing of your PI. You may request objection, restriction and portability rights by contacting us at the contact information provided in Section “Contact Us“, below.

Portability. You may request portability of your PI.

Withdraw Consent. If we have collected and processed your PI with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your PI conducted in reliance on lawful processing grounds other than consent.

File a complaint. You have the right to file a complaint with a supervisory authority about our collection and processing of your PI.

Links to Other Services

In certain sections of our Services, we may include links to third-party websites or applications (for example, Facebook and Twitter). These websites and applications are governed by their own privacy policies or information collection practices, which may be substantially different from ours. We do not guarantee and are not responsible for the privacy or security of these websites, including the accuracy, completeness or reliability of information found on these websites. If you follow links to websites not affiliated or controlled by us, we encourage you to review the privacy policies and information collection practices of any external websites and apps, as those parties’ practices would not be subject to this Policy.

Location of Information Processing

Our Services are controlled and operated by us from the United States. Your information may be stored and processed in any country where we have facilities or in which we engage service providers, including the United States, which may have data protection laws that are different

from those of your country. In addition, your information may be subject to access requests from governments, courts, or law enforcement officials in countries where it may be processed, under the laws of those countries.

Security

The security of your PI is important to us, and we employ physical, technical, and administrative security measures designed to safeguard the information collected by the Services. We use industry standard SSL (secure socket layer technology) encryption to transfer PI. Other security safeguards include, but are not limited to, data encryption, firewalls, and physical access controls to buildings and files. We also conduct periodic audits of our security (no less than annually) to apply best practices and reasonable industry standards. However, no data transmission over the Internet can be guaranteed to be completely secure. If there is a breach of our security, we will notify you where required by law or deemed necessary and appropriate under the circumstances.

Account holders create a password in the registration process. You can help protect against unauthorized access to your Account and PI by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account. At registration, we assign a Member ID to each Account and use those Member IDs to authenticate logins, allow access to the subscription content, and monitor compliance. The Member ID is also used to authenticate users when requesting technical support. Access to information is limited (through user/password credentials and two-factor authentication) to those employees who require it to perform their job functions.

Some of the precautions we take to protect PI includes: (a) limiting employee access to PI to only those employees with a need to such access to fulfill their job responsibilities; (b) conducting background checks on our employees and, specifically, upon all employees that may have access to PI; (c) requiring employees to sign confidentiality agreements upon hiring; (d) conducting regular employee privacy and data security training and education; and (e) protecting PI with commercially reasonable technical, contractual, administrative, and physical security safeguards.

Please be aware, however, that no information system can be guaranteed to be 100 percent secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Services over networks that we do not control, including the internet and wireless networks. If you have reason to believe that your interaction with us is not secure, please contact us as described in Section “Contact Us“ below.

Changes to Our Privacy Policy

We constantly try to provide the best services, and accordingly our Policy will change from time to time. If we substantially update this Policy, we will notify you by posting the revised Policy on our Services, and for certain revisions that materially expand the ways in which we use or share the information previously collected from you through the Services, either display an alert next to the Policy, display an alert upon login to the Services, or directly communicate with you (e.g. via our messaging service or the email address associated with your Account).

Contact Us

SATARANJI AFRICA is in the United States of America and we are the operator for all our Services. You may contact Support if you have any questions, complaints, or other issues related to this Policy and issues related to your information.

For all Accounts Mailing address:

SATARANJI AFRICA 50533-00100

Nairobi, Kenya

Contact Support here

Chess Play & Learn (Arcade Version)

This Section contains the provisions that only apply specifically to our mobile application known as Sataranji – Play & Learn (the “App“). This section is intended to complement the Policy above and it does not apply to our Sites or other Services.

Data Collection and Use

The App collects non-identifiable gameplay data to send to Apple iCloud, specifically to record a User’s progress (win record) vs. the App’s built-in roster of computer opponents. We do not store any of this data, but it is sent to Apple services (iCloud and Game Center) for storage and use.

The App also collects the User’s anonymized Game Player ID for the App’s “Online Play“ feature, where it is used to maintain a chess skill rating as online games are played. This helps ensure Users are matched with opponents of similar skill levels.

The Game Player ID is also used to maintain a list of chess puzzles the User has solved in the App’s “Daily Puzzle“ feature and may also be used for other App features if that is necessary to fulfill a User request. The processing of this data is subject to your consent and you are able to revoke such consent by changing the settings from your device.

The App is available to Users through the different app stores and collects non-identifiable gameplay data from all Users. The basis for this collection of information is to support the internal operations of the App and your consent in some cases.

SUBSCRIBER AGREEMENT

Effective date: 30/11/2024

Paid subscriptions to SATARANJI AFRICA and other services on this site are governed by the following terms and agreement:

Payments

Payments for subscriptions may be made via credit card, PayPal, iTunes, Google Play, money order, or other payment methods. All subscriptions are processed in USD or Kshs unless otherwise shown.

Gift subscriptions are charged once only and do not renew. All other subscriptions are auto- renewed until canceled by the subscriber through their account, or by contacting Member Support. Payments made by mail should identify the subscription product and should be sent to PO Box 50533 Nairobi, Kenya. Please see our Privacy Policy for further information regarding our use and storage of payment information. This Subscriber Agreement is subject to any limitations set forth in the Privacy Policy.

Services

Subscribers are authorized to receive the services outlined on the subscription page for the duration of their subscription. Services are effective immediately upon receipt of payment. As with any online subscription service, we cannot guarantee that SATARANJI AFRICA or any of the Services will be free of downtime for maintenance or other outages. Where possible, we may notify you in advance of planned outages.

We reserve the right to change our subscription prices from time to time. Price changes will not affect an existing subscription that you have already purchased during the duration of the subscription period. However, price changes will apply to new subscriptions and may apply to subsequent renewals of an existing subscription. We will inform you of any change(s) in price within a reasonable time before the change(s) take effect. If you do not agree to such a change, you may cancel the subscription.

Upgrades/Downgrades

Upgrading can be done at any time and the upgrade price MAY be pro-rated according to the time used and time remaining. The upgrade price will show in the checkout process. Downgrades are not available until after the expiration of the original subscription. For help, please contact Member Support.

Refunds

If you are not satisfied, please contact Member Support. All first-time credit card and Android subscriptions are given a 30-Day Money Back Guarantee. Refunds will NOT be given to subscribers who are banned from the site due to violating the Terms and Conditions of site use (abusive behavior, cheating, etc).

Subscribers via iTunes are subject to Apple’s Subscription terms. Unfortunately, Apple does not provide a way for SATARANJI AFRICA to refund iTunes payments, and all refunds and claims must be made directly via Apple. Please see https://support.apple.com/en-us/HT202039.

ALL CRYPTO TRANSACTIONS ARE NON-REFUNDABLE.

If you have any questions regarding the above policies please contact us.

FAIR PLAY POLICY

Last updated: 30/11/2024

SATARANJI AFRICA’s Fair Play Policy supports our mission to maintain a clean and fair platform for chess players around the world. In light of this mission, we reserve the right and discretion to monitor all chess games played on our platform.

You agree to support our mission of maintaining a clean and fair platform by not engaging in any dishonest, deceitful, fraudulent, or other similar conduct when playing on our platform or in our events, including the following:

• 
  All of your moves must be your own.
• 
  Do not cheat in any way.
• 
  Do not get help from any other person, including parents, friends, coaches, or another player.
• 
  Do not use chess engines, software of any kind, bots, plugins, browser extensions, or any tools that analyze positions during play. We can detect if you are using any of these programs.
• 
  Do not use tablebases or any other resources that show the best move (in both Online and Daily chess).
• 
  You may use Opening Explorer or other books in Daily chess only (not in Online / Live play).
• 
  Do not perform any automated analysis or “blunder checking“ of your games in progress.
• 
  Do not allow anyone else to use your account.
• 
  Do not use anyone else’s account.
• 
  Do not artificially manipulate ratings, matches, or game outcomes.
• 
  Do not interfere with the gameplay of other members.
• 
  Suspecting your opponent of using outside help is not an excuse to do the same. If you suspect someone is cheating, report the player to SATARANJI AFRICA.

NOTE: This Fair Play Policy applies to your use of our Services; however, it does not apply to your games that are not against other users, such as in the game mode versus SATARANJI AFRICA computer (i.e., non-human, virtual) “bots“. However, please note that we may expand or narrow any applicable exceptions to the Fair Play Policy at any time without notice to you, so you should remain familiar with this policy.

WARNING: Consistent with our User Agreement, if we determine or suspect that you have violated our Fair Play Policy in any way, then we may close your account and label it publicly closed for Fair Play violation(s). We also reserve and maintain the complete right to take any action that we may deem appropriate in response to a violation(s) or suspected violation(s) of our Fair Play Policy, including but not limited to publicly disclosing facts, communications, and findings regarding any violation(s) of the Fair Play Policy and disclosing such materials to governmental authorities or chess governing bodies. All account status changes are made at our sole discretion. Under some circumstances, including for titled players, we may, at our

discretion, allow you to open a second-chance account, subject to additional terms and conditions, including your provision of a written acknowledgement of your violation(s) in the form of an agreement we provide. If further violations of the Fair Play Policy are detected, you may be subject to a lifetime ban from SATARANJI AFRICA. For the avoidance of doubt, SATARANJI AFRICA has no obligation to provide second-chance accounts, even for titled players, and reviews Fair Play Policy violations on a case-by-case basis.

Our User Agreement also has specific rules of conduct and other restrictions that users must abide by when using the Services. As a condition of your use of our Services, you must abide by both this Fair Play Policy and our User Agreement. In the event of any conflict between our User Agreement and this Fair Play Policy, our User Agreement will supersede. All capitalized terms used but not defined in this Fair Play Policy have the respect meanings set forth in the User Agreement.

We reserve the right to modify this policy at any time with or without notice to you, in which case we will update the “Last updated“ date at the top of this Fair Play Policy.

COMMUNITY POLICY

Effective date: 30/11/2024

SATARANJI AFRICA’s vision is to become the largest African chess community with millions of active members representing every country on the planet. Our goal is to create a fun, safe, and fair place for all chess fans to enjoy the game.

We expect all members to treat others respectfully and to follow the specific guidelines below. Players and community members who are unable to follow these rules will be subject to warnings, restricted privileges, separated playing pools, or even having their accounts closed. We reserve the right to change the Community Policy at any time. Compliance with the Community Policy does not constitute guaranteed future access to SATARANJI AFRICA or use of the Service.

Community Conduct

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  Be kind, helpful, and forgiving
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  We will not tolerate racism, sexism, bigotry, or violent threats
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  Do not abuse, attack, threaten, discriminate, harass, or mistreat other members in any way
• 
  Do not hijack threads, troll, or post distracting or meaningless content
• 
  Do not post spam, advertisements, or copy/paste comments and messages
• 
  Do not excessively promote your club
• 
  Do not publicly debate religious or political topics
• 
  Do not post obscene or pornographic content
• 
  Do not discuss illegal activities
• 
  Do not open more than two accounts (a second, anonymous account is allowed for training purposes only)
• 
  Do not publicly accuse your opponents of cheating (you should instead privately report them)

Sportsmanship

• 
  Do not abort games frequently
• 
  Do not make your opponents wait unnecessarily
• 
  Do not disconnect or quit without resigning when lost
• 
  Follow Fair Play Policy

If you have any questions about our policies, please reach out to our Support Team.

COMPETITIVE EVENTS POLICY

Last updated: 30/11/2024 Introduction

SATARANJI AFRICA runs tournaments and events with prizes (monetary, or other) (“Competitive Events“) that are open to professional and aspiring chess players. Our goal is to create tournaments that are fun, professional, and fair.

This Competitive Events Policy constitutes a legally binding agreement between you and SATARANJI AFRICA, and supplements our general User Agreement, which also applies to Competitive Events. This Competitive Events Policy is incorporated by reference into, and forms a part of, our User Agreement. In the event of a conflict between the terms of this Competitive Events Policy and our User Agreement, this Competitive Events Policy will supersede and control but only with respect to the applicable Competitive Event. All capitalized terms used but not defined in this Competitive Events Policy have their respective meanings set forth in our User Agreement.

To play in Competitive Events, you must be an adult of lawful age under the laws applicable to the location in which you reside and capable of lawfully entering into a contract. By playing in a Competitive Event, you are agreeing to this Competitive Events Policy, our User Agreement, our Fair Play Policy, and all of our Terms. You also will be required to read, agree to, comply with, and if applicable, sign all related participation agreements, prize agreements, and other event agreements that SATARANJI AFRICA provides to you pertaining to such Competitive Events (collectively, the “Event Agreements”), as well as the Official Rules pertaining to such Competitive Event. If you are not of lawful age, then your parent or legal guardian must consent to your participation in a Competitive Event, this policy, and all other related agreements.

SATARANJI AFRICA is not responsible for verifying the legality of your participation in its Competitive Events.

In case of disputes or disagreements concerning any aspect of a Competitive Event including but not limited to all matters relating to the awarding of prizes, your eligibility to participate in the Competitive Event, the conduct of any player, this policy, SATARANJI AFRICA’s User Agreement, Fair Play Policy, Community Policy, the applicable Official Rules, and Event Agreements, and any other applicable terms and conditions in connection with your obligation to follow any instructions given to you by our team or in relation to any matter concerning your participation in a Competitive Event, we will have sole authority to decide and our decision will be final and binding upon you and shall not be subject to review or appeal by you or any third party.

ARBITRATION NOTICE: OUR USER AGREEMENT CONTAINS AN ARBITRATION PROVISION. PLEASE REVIEW THE ARBITRATION PROVISION IN OUR USER AGREEMENT CAREFULLY SINCE IT AFFECTS YOUR RIGHTS. BY PLAYING IN A COMPETITIVE EVENT, YOU UNDERSTAND AND AGREE TO BE FULLY AND COMPLETELY BOUND BY SUCH ARBITRATION PROVISION.

Eligibility

All Competitive Events are subject to eligibility requirements determined at SATARANJI AFRICA’s sole discretion. Eligibility criteria may include but are not limited to, gender, age, compliance with Fair Play Measures (outlined in the following section), SATARANJI AFRICA account statistics, such as leaderboard rankings and ratings, and information registered with recognized chess federations such as federation affiliation, FIDE ratings, and titles (e.g.

Grandmaster). If you wish to participate in a Competitive Event, you must include your full name on your SATARANJI AFRICA profile. Further, you are only eligible to participate in any Competitive Event if such participation does not violate applicable local laws. You are fully responsible for ensuring that your participation in the Competitive Event is compliant with all laws of the jurisdiction(s) in which you are a resident and must take all steps necessary to ensure such compliance, including the federal, state, and local laws of the United States applicable to jurisdictions outside the United States. For the avoidance of doubt, SATARANJI AFRICA does not take responsibility for your compliance with applicable law. Specific eligibility criteria for a Competitive Event will be specified in such Competitive Event’s Official Rules.

Fair Play Measures

You must comply fully with our Fair Play Policy. In addition, you may be asked to comply with additional fair play requests determined by SATARANJI AFRICA that are intended to uphold the competitive integrity of all Competitive Events. Failure to comply with fair play requests may result in penalties and/or removal from Competitive Events at SATARANJI AFRICA’s sole discretion. Fair play requests include, but are not limited to, any or all of the following:

Video Monitoring

Upon request, you may be required to join a video conference call with up to two cameras for monitoring by SATARANJI AFRICA. One camera must clearly show your full face and immediate surroundings. If a second camera is requested, it should be placed behind you diagonally at an approximate 30-degree angle on your mouse hand-side with your desk, PC (or applicable device), and monitors clearly visible (the specific angle may change depending on the circumstances). You may also be requested to share your entire computer screen for the entire duration of your games.

Environment Requirements

You may be asked to comply with various requirements pertaining to your physical playing area (“Environment“) during a Competitive Event. Such requirements may include being alone in your environment and keeping your desk or table free of clutter or visual obstructions. You may also be requested to not have any personal electronic devices, other than those used for playing or monitoring, on or near your person during a Competitive Event.

Equipment Requirements

You may be asked to comply with various equipment requirements during a Competitive Event. Such requirements may include not wearing headphones or earpieces, playing on only desktop

computers or laptops using keyboard and mouse, turning off additional monitors or having them visible on a camera, and/or closing all applications and browser tabs except the specific browser and browser tab being used to play on SATARANJI AFRICA.

Monitoring Software

You may be required to install and use software on your computer or device during a Competitive Event that monitors your activity on your computer or device. When using this monitoring software your computer or device must meet specific minimum standards. Details regarding these standards will be made publicly available online in advance of the event. It is your responsibility to review these standards to ensure your equipment complies. This software may log your device processes and tabs, record your device screen, access your camera(s) and video, record your input and output audio, and track your mouse or cursor movement, without prejudice to other information that may be accessed by the software, provided that such information and the purposes for its collection are disclosed to you before the collection.

Inspections

Prior to and during a Competitive Event, you may be asked to submit to physical inspections, environment inspections, and computer inspections upon request by SATARANJI AFRICA. During a physical inspection, you may be requested to remove any glasses or eyepieces and show them to SATARANJI AFRICA using a camera. You may also be requested to turn your head to one side, brush your fingers over your ear, and then repeat this process for the other side. During an environment inspection, you may be requested to show SATARANJI AFRICA the layout and contents of your environment using a camera. During a computer inspection, you may be requested to provide a screen share of any monitors, computer’s display and audio settings and/or requested to view your task manager (PC) or activity monitor (Mac).

Broadcasting

You are not permitted to broadcast or distribute any video conference call, in whole or in part, used for monitoring in connection with any Competitive Event without our previous express authorization. If you choose to broadcast your gameplay, you may be required to disable any live chat functionality, use “emote-only“ mode, and/or implement a delay of at least 60 seconds.

Proctoring

You may be requested to cooperate with an on-site proctor for a Competitive Event. If such a request is made, SATARANJI AFRICA will coordinate with you for a SATARANJI AFRICA staff member or SATARANJI AFRICA-approved proctor to be assigned to inspect your playing area, clothing, camera setup, computer, and any related components of any nature. You also consent to any additional security and anti-cheating measures employed by SATARANJI AFRICA, including but not limited to a full body sweep with a metal detector or any other security device, a reasonably non-intrusive body pat down, and the proctor observing your play during the Competitive Event. You furthermore must comply with any other Competitive Event- related security and anti-cheating measures requested by the proctor, including those that occur after match start.

Competitive Event Gameplay

Unless stated otherwise in a Competitive Event’s Official Rules, all gameplay will take place on SATARANJI AFRICA’s live server online and be subject to the following policies related to gameplay:

Player Actions

All in-game actions, including but not limited to chess moves, premoves, promotions, draw offers, or resignations made by you will be deemed final. There will be no “takebacks“ due to actions unintentionally made by you for any reason. If you accidentally lose on time, that result will be deemed final.

Connection Issues

If you disconnect during a game, your clock will continue to run until it expires or until a move is made. SATARANJI AFRICA staff, at their sole discretion, may permit additional time between games for you to resolve connection issues.

Punctuality

For any Competitive Event with a video monitoring requirement, you must be present in the designated proctoring call by a communicated call time.

Forfeits

You may be subject to penalties for forfeiting a match.

Communications

Unless otherwise stated in a Competitive Event’s Official Rules, you are prohibited from communicating with any individual during a match except for designated SATARANJI AFRICA staff.

Conduct

Personal Conduct

You are required to adhere to SATARANJI AFRICA’s Community Policy. Conduct deemed by SATARANJI AFRICA to involve bullying, harassment, or otherwise persistently disrespectful behavior towards other players is prohibited. This encompasses all oral or written statements or remarks, whether made in person, online, or via social media.

Match Conduct

You must make reasonable effort to always compete to the best of your ability. Collusion, defined as intentional cooperation to cheat or deceive other players, and match-fixing, defined as any offer, agreement, or attempt to influence the outcome of a game or match, are strictly prohibited. Draws offered and accepted in-game, in good faith, are permitted unless otherwise prohibited by the applicable Official Event Rules.

Dress Code

If you are requested to join a video conference call, you must wear attire that respects public norms, as determined at SATARANJI AFRICA’s sole discretion.

Rules Violations

Investigation

You must fully cooperate with SATARANJI AFRICA and/or SATARANJI AFRICA staff in any investigation pertaining to possible violations of the requirements set forth in this policy. If you are found to have withheld or tampered with relevant information or found to have misled SATARANJI AFRICA and/or SATARANJI AFRICA staff in an investigation, you will be subject to disciplinary action.

Disciplinary Action

If SATARANJI AFRICA or its staff conclude or suspect that you have violated this policy, any of its other policies (including SATARANJI AFRICA’s Fair Play Policy), or a Competitive Event’s Official Rules, SATARANJI AFRICA and/or its staff reserve the right to take any action at their sole discretion deemed appropriate in response to such violation(s), which may include the following disciplinary actions:

• 
  Warning
• 
  Game or match restart
• 
  In-game time reduction
• 
  Game or match forfeiture
• 
  Removal from any ongoing Competitive Events
• 
  Partial or full forfeiture of prize money in connection with Competitive Events
• 
  Suspension from participating in other Competitive Events organized by SATARANJI AFRICA
• 
  Closing your account
• 
  Publicly and permanently marking your account as closed due to Fair Play violation
• 
  Public disclosure of facts, communications, suspicions, findings, and account status regarding any potential violation(s)
• 
  Disclosing facts, communications, suspicions, findings, and account status regarding any potential violation(s) to governmental authorities or chess governing bodies, including FIDE
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  Additional disciplinary action specified in the SATARANJI AFRICA User Agreement

Disputes

SATARANJI AFRICA maintains all final decisions and disciplinary actions as it pertains to rules violations, including breach, enforcement, or interpretation thereof.

Prizes

If you win any Prize (monetary, or other) in any Competitive Event on SATARANJI AFRICA, you acknowledge and consent to SATARANJI AFRICA’s ongoing investigation of your games whether related or unrelated to those occurring within the event and that any judgment made as a determination of your eligibility to win any Prize or a disqualification thereof shall lie with SATARANJI AFRICA. SATARANJI AFRICA may, at its sole discretion, withhold any and all Prizes won in any Competitive Event on our Site for any period of time pending investigation into your Games. Any decision by SATARANJI AFRICA regarding forfeiture, reduction or cancellation of Prizes in accordance with SATARANJI AFRICA’s User Agreement shall be final and binding upon you and shall not be subject to review or appeal by you or any third party.

Prize eligibility may be contingent upon adherence to event-specific fair play measures, which may include, but not be limited to video and audio monitoring, physical and environmental inspections, as well as in-person supervision.

We aim to deliver any money Prize you win within three weeks of receiving a full and accurate claim from you, barring any unforeseen circumstances beyond our control.

SATARANJI AFRICA does not and cannot provide tax advice or legal advice regarding the tax disposition of any Prizes. SATARANJI AFRICA may disclose information related to Prizes to any tax authority it deems necessary, including by way of response to a valid request for information by any governmental body making such a request. Without limiting the generality of the foregoing, SATARANJI AFRICA may or may not provide notice to you of such disclosures in its sole discretion, which may constitute a limitation upon your privacy rights under the GDPR or the analogous data privacy laws of your jurisdiction.

General Prize Restrictions

You will not be declared an official winner until you execute and provide us with (or, if you are a minor, your parent or legal guardian executes) all documents required by SATARANJI AFRICA, where applicable, such as a prize agreement, payment information,tax forms or other “Winner Forms“ in order to receive payment. If you (or in case you are a minor your parent or legal guardian) fail or refuse to sign and return all the Winner Forms within ten (10) days (or a shorter time if required by exigencies) after receiving them, you may be disqualified. In the event you are disqualified, SATARANJI AFRICA reserves the right, but not the obligation, to award the affected prize to the player that last lost to you or followed you in the Event’s standings.

Within sixty (60) days of receiving an executed copy of the Winner Forms, SATARANJI AFRICA will deliver to you the applicable prize(s). Failure to take delivery of any prize may result in forfeiture, and such prize awarded to an alternate winner. Prizes may not be transferred or assigned until after you have complied with all your obligations under these Rules. No substitutions may be made for prize(s), except by SATARANJI AFRICA, who reserves the right to substitute a prize in whole or in part with another prize of comparable or greater value if the intended prize is not available for any reason as determined by SATARANJI AFRICA in its sole discretion. By participating in a Competitive Event, you acknowledge that SATARANJI AFRICA staff have not and will not obtain or provide insurance of any kind relating to the prizes. You will be responsible for all taxes (including but not limited to federal, state, local and/or income) on any prize won and on the value of any items or value transferred to you by

SATARANJI AFRICA, and will be required to provide your Social Security number, IRS Form W-9, IRS Form W-8BEN, IRS Form W-8BEN-E, or equivalent information for tax reporting purposes (at a time to be determined in SATARANJI AFRICA’s sole discretion, and which may be prior to participation in a particular round or prior to receipt of any prize). SATARANJI AFRICA will file an IRS Form 1099 or equivalent tax withholding documentation for the retail value of any prize or other items of value transferred to you by SATARANJI AFRICA in accordance with IRS requirements, and SATARANJI AFRICA may also share such documentation with a state or local government agency as required by law. Refusal or failure for you to satisfy the requirements of all necessary and appropriate tax, withholding or other required compliance terms (including Social Security number, IRS Form W-9, IRS Form W- 8BEN, IRS Form W-8BEN-E, or equivalent information), as determined by SATARANJI AFRICA in its sole discretion, will result in your forfeiting the prize(s) and an alternate winner being selected in accordance with these Rules. If you do not claim the prize or satisfy the information or documentation requirements within six (6) months of the close of the Competitive Event or such earlier time as designated by SATARANJI AFRICA, are void, and SATARANJI AFRICA shall have no further liability or responsibility to you in connection with the prizes.

Any prizes pictured in advertising, promotional and/or other Competitive Event materials are for illustrative purposes only. The actual prize may vary. In the event there is a discrepancy or inconsistency between the description of a prize contained in any such materials and the description of a prize contained in the Official Event Rules, these Rules shall prevail, govern and control. All details and other restrictions of any prize not specified in Official Event Rules will be determined by SATARANJI AFRICA in its sole discretion.

Appearance Release

By participating in the Competitive Event, you hereby irrevocably grant SATARANJI AFRICA and each of its respective licensees, successors and assigns, permission to stream, film, photograph and record your performance in the Competitive Event itself and in other Competitive Event-related activities, including your name, SATARANJI AFRICA username, logo, avatar, gamertag or equivalent, voice, statements, image, likeness, in-home location, and other personal characteristics, information and so-called publicity rights as they appear therein (collectively, the “Appearance“) and the right, but not the obligation, to distribute, exploit or otherwise use such Appearance, in whole or in part, in any and all media, now known or hereafter devised, throughout the universe in perpetuity, for any purpose, including but not limited to, advertising, marketing and promoting the Competitive Event, the SATARANJI AFRICA website, SATARANJI AFRICA staff, and future Competitive Events.

SATARANJI AFRICA grants you a revocable, non-exclusive, non-transferable, non- sublicensable right and license to use SATARANJI AFRICA marks solely as necessary for promotion of the Event. You and SATARANJI AFRICA shall use the other party’s marks solely in accordance with the other party’s trademark usage guidelines and quality control standards as the same may be updated from time to time. Neither party shall use, register, or attempt to register in any jurisdiction any mark that is confusingly similar to or incorporates any of the other party’s marks. All uses of a party’s marks, and all goodwill associated therewith, shall

insure solely to the benefit of such party, and each party shall retain all right, title and interest in and to his/her/its marks.

Indemnification

You shall indemnify, defend and hold harmless SATARANJI AFRICA and each of its respective agents, representatives, parent companies, affiliates, subsidiaries, legal advisors, officers, directors, employees, shareholders, equity interest holders, directors, successors and assigns, as applicable from and against any and all losses, damages, liabilities, deficiencies, claims, actions, judgments, settlements, interest, awards, penalties, fines, costs, or expenses of whatever kind, including reasonable attorneys’ fees, the cost of enforcing any right to indemnification hereunder and the cost of pursuing any insurance providers (collectively, “Losses“), resulting from any claim, suit, action or proceeding (each, an “Action“) arising out of or related to: (i) your conduct, including your advertising, marketing or promotion of SATARANJI AFRICA or its marks or materials; (ii) any use, presentation, display or distribution of SATARANJI AFRICA marks or materials in a manner not expressly permitted by Official Event Rules; or (iii) your breach of any representation, warranty, covenant, or the obligations herein as well as the SATARANJI AFRICA’s User Agreement, Fair Play Policy, Community Policy, the applicable Official Rules, and Event Agreements.

SATARANJI AFRICA shall indemnify, defend and hold harmless you, as applicable from and against any and all Losses resulting from any Action arising out of or related to SATARANJI AFRICA’s breach of any representation, warranty, covenant, or obligations herein.

Release and Limitation of Liability

By participating, you agree that SATARANJI AFRICA and each of its respective agents, representatives, parent companies, affiliates, subsidiaries and legal advisors, officers, directors, employees, shareholders, directors, successors and assigns (“Released Parties“) are not responsible or liable for, and shall be released and held harmless from: (i) late, lost, delayed, damaged, incomplete, illegible, unintelligible, misdirected or otherwise undeliverable mail, postage-due notices, release forms, affidavits or other correspondence; (ii) telephone, electronic, hardware or software program, network, internet or computer malfunctions, failures, or difficulties of any kind; (iii) any condition caused by events beyond the control of SATARANJI AFRICA that may cause the Competitive Event to be disrupted or corrupted; (iv) any printing, human, typographical or other errors or ambiguities in (or involving) any materials associated with the Competitive Event; (v) any and all losses, damages, rights, claims and action of any kind in connection with or resulting from your participation in the Competitive Event; (vi) acceptance, possession, or use of any prize, including without limitation, personal injury, death and property damage arising there from; and (vii) claims based on publicity rights, defamation or invasion of privacy. SATARANJI AFRICA reserves the right, in its sole discretion, to suspend or cancel the Competitive Event at any time for any reason, including, without limitation, if a computer virus, bug or other technical problem corrupts the administration, security, or proper conduct of the Competitive Event, strikes, lock-outs, acts of God, technical difficulties, and other events not within the reasonable control of SATARANJI AFRICA.

BY PARTICIPATING IN ANY COMPETITIVE EVENT, YOU AGREE THAT THE RELEASED PARTIES WILL HAVE NO LIABILITY WHATSOEVER FOR, AND SHALL BE HELD HARMLESS BY YOU AGAINST ANY LIABILITY FOR ANY INJURIES, LOSSES, OR DAMAGES OF ANY KIND TO PERSONS, INCLUDING PERSONAL INJURY OR DEATH, OR PROPERTY RESULTING IN WHOLE OR IN PART, DIRECTLY OR INDIRECTLY, FROM ACCEPTANCE, POSSESSION, MISUSE, OR USE OF THE PRIZE, ENTRY OR PARTICIPATION IN THIS COMPETITIVE EVENT OR IN ANY COMPETITIVE EVENT-RELATED ACTIVITY, OR ANY CLAIMS BASED ON PUBLICITY RIGHTS, DEFAMATION, OR INVASION OF PRIVACY, OR MERCHANDISE DELIVERY. THE RELEASED PARTIES ARE NOT RESPONSIBLE IF ANY PRIZE CANNOT BE AWARDED DUE TO TRAVEL CANCELLATIONS, DELAYS, OR INTERRUPTIONS DUE TO ACTS OF GOD, ACTS OF WAR, NATURAL DISASTERS, WEATHER, OR TERRORISM.

WITHOUT LIMITING THE FOREGOING, EVERYTHING REGARDING THIS PROMOTION, INCLUDING THE COMPETITIVE EVENT HOMEPAGE AND ALL PRIZES, ARE PROVIDED “AS IS“ WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON- INFRINGEMENT. SOME JURISDICTIONS MAY NOT ALLOW THE LIMITATIONS OR EXCLUSIONS OF LIABILITY FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES OR EXCLUSION OF IMPLIED WARRANTIES, SO SOME OF THE ABOVE LIMITATIONS OR EXCLUSIONS MAY NOT APPLY. CHECK LOCAL LAWS FOR ANY RESTRICTIONS OR LIMITATIONS REGARDING THESE LIMITATIONS OR EXCLUSIONS.

General Terms and Conditions

The laws of the State of Utah govern all Competitive Events. All issues and questions concerning the construction, validity, interpretation, and enforceability of any Competitive Event, or your rights and obligations and SATARANJI AFRICA in connection with a Competitive Event, shall be governed by, and construed in accordance with, the laws of the state of Utah, without giving effect to any choice of law or conflict of law rules or provisions (whether of Utah or any other jurisdiction) that would cause the application of the laws of any jurisdiction other than the state of Utah. In the event of a claim or dispute, your sole remedy shall be limited to their remedy at law for damages, if any, and you shall not have the right to in any way enjoin or restrain the distribution, advertising, publicizing, or other exploitation (in any form of media) of any Competitive Event website, any Competitive Event, and/or any intellectual property owned or licensed by SATARANJI AFRICA or its respective parent companies, subsidiaries, member stations, or affiliated entities. SATARANJI AFRICA reserves the right, at its sole discretion, to prohibit any player from participating in any Competitive Event or to disqualify any individual it finds, in its sole determination, to be tampering with the entry process or the operation of any Competitive Event; to be attempting to undermine the legitimate operation of the Competitive Event by cheating, hacking, deception, or any other unfair playing practices; to be acting in violation of the Rules; or to be acting in a disruptive manner, or with intent to annoy, abuse,

threaten, or harass any other person. SATARANJI AFRICA may suspend or discontinue any Competitive Event if, in its sole opinion, there is any actual or suspected tampering of such Competitive Event, or any other malfunction, event or activity that may affect the integrity of such Competitive Event. SATARANJI AFRICA may, for any reason, and at any time before, during, or after a Competitive Event, remove you and/or any other players from the event. Even if you have been previously invited to a Competitive Event by SATARANJI AFRICA, SATARANJI AFRICA may, at its sole discretion, exclude you from the event without notice.

SATARANJI AFRICA SHALL NOT BE OBLIGATED TO AWARD ANY PRIZE THAT RELATES TO OR ARISES OUT OF IMPROPER OR MISTAKEN PRIZE NOTIFICATION, OPERATION OR FUNCTION OF ANY COMPETITIVE EVENT. SATARANJI AFRICA shall

not be liable to you for any failure to perform any of our obligations under the Competitive Event or any related Prizes should SATARANJI AFRICA be unable to do so as a result of circumstances beyond our reasonable control. We reserve the right, at any time, to amend at our sole discretion these Competitive Events Policy, in which case we will update the “Last Revised“ date at the top of this Competitive Events Policy. Any changes to this Competitive Events Policy will be in effect as of the “Last Revised“ date referred to at the top of this page. When required by applicable law, we will announce any changes to any Competitive Event and your continued participation in that Competitive Event shall be deemed an acceptance of those changes.

Privacy Policy

Any personal information supplied by you to SATARANJI AFRICA will be subject to SATARANJI AFRICA’s privacy policy. By entering the Competitive Event, you grant SATARANJI AFRICA permission to share your email address and any other personally identifiable information with any co-sponsor solely for the purpose of administration and prize fulfillment. SATARANJI AFRICA will not sell, rent, transfer, or otherwise disclose your personal data to any third party other than as described above herein or in the privacy policy.

Rules and Winners List

For a copy of a Competitive Event’s Official Rules and/or Winners List, visit SATARANJI AFRICA or send a self-addressed, stamped envelope for receipt within three months of such Competitive Event’s conclusion to: Rules/Winners List, [Name of Competitive Event], c/o SATARANJI AFRICA, 50533-00100 Nairobi, Kenya.

GIFTING POLICY

Effective date: 30/11/2024

Acceptance of Policy

When you use our Gift Membership Service, you agree to this Policy and to all of the sections included within our User Agreement. If you do not agree to this Policy or our User Agreement, then you may not use our Gift Membership Service.

A Gift Membership is a membership paid for by one person (the “Purchaser”) for someone else (the “Recipient”). A Purchaser and Recipient cannot be the same party. On the day the Purchaser successfully completes the purchase of a Gift Membership (the “Purchase Date”), SATARANJI AFRICA will create an order confirmation number for the Purchaser. Gift Memberships, unlike other SATARANJI AFRICA Memberships, are non-renewing and allow access to SATARANJI AFRICA Memberships by the Recipient only from the date when the Gift Membership begins (the “Gift Start Date”) through the duration of the membership purchased (the “Gift Term”). Any purchase or use of Gift Memberships is subject to this Policy, which is in addition to and does not replace the general SATARANJI AFRICA User Agreement.

Purchasing a Gift Membership

Gift Memberships may only be purchased at SATARANJI AFRICA. Specific terms and conditions set forth in the purchase process may apply. At the time of purchase, the Purchaser will choose the date on which the Gift Membership will be presented to the Recipient (the “Gift Delivery Date”), which must be within 90 days of the Purchase Date. SATARANJI AFRICA will generate the Gift Membership that will allow the Recipient to access the Gift Membership on the Gift Delivery Date, and SATARANJI AFRICA will email the recipient, and/or additionally send a SATARANJI AFRICA Inbox Message, if applicable, on the Gift Delivery Date. SATARANJI AFRICA also will send a “receipt email” to the Purchaser on the Purchase Date with an order confirmation number for the Gift Membership.

SATARANJI AFRICA is not responsible and assumes no liability for non-delivery of an email because of an invalid address, Purchaser incorrectly applied email address, spam filters, or any other reason. If the Purchaser wishes to have the gift announced on the Gift Delivery Date in some way other than SATARANJI AFRICA announcing it via email or SATARANJI AFRICA Inbox Message, then the Purchaser is solely responsible for doing so.

Accessing a Gift Membership

If the Purchaser uses the Recipient’s SATARANJI AFRICA username to deliver the Gift Membership:

The Gift Start Date (i.e., when the Gift Membership begins) will be the same date as the Gift Delivery Date and conclude at the end of the Gift Term, regardless of whether the Recipient accesses the Membership on the Gift Start Date, a later date or never.

If the Purchaser uses the Recipient’s email address to deliver the Gift Membership, and either:

1. If the Recipient has a SATARANJI AFRICA account prior to Gift Delivery Date, and the email address associated to the Gift Membership matches the email address associated with the

Recipient’s SATARANJI AFRICA account:

The Gift Start Date (i.e., when the Gift Membership begins) will be the same date as the Gift Delivery Date and conclude at the end of the Gift Term, regardless of whether the Recipient accesses the Membership on the Gift Start Date, a later date or never.

1. If the Recipient has a SATARANJI AFRICA account prior to Gift Delivery Date, and the email address associated with the Gift Membership does NOT match the email address associated with the Recipient’s SATARANJI AFRICA account:

The Gift Membership will not start under the Recipient’s existing SATARANJI AFRICA account. To begin the Gift Membership, the Recipient can either (a) contact SATARANJI AFRICA Support; or (b) establish a new SATARANJI AFRICA account using the Recipient’s email address associated with the Gift Membership. Immediately upon creation of that new SATARANJI AFRICA account, the Gift Term will begin.

1. If the Recipient does not have a SATARANJI AFRICA account prior to Gift Delivery Date;

To begin the Gift Membership, the Recipient must create a SATARANJI AFRICA account with the same email address associated with the Gift Membership. Immediately upon creation of that new SATARANJI AFRICA account, the Gift Term will begin.

Refunds and notice of non-transferable

Gift Memberships are not refundable except as required by applicable law. Gift Memberships may not be resold or transferred. A Gift Membership is not valid and will not be honored, and SATARANJI AFRICA will not be liable for the value of the Gift Membership, if the Gift Membership is obtained from an unauthorized seller or reseller, including through any Internet auction site.

Single-Use Only; Not Combinable with Other Offers; Not Exchangeable.

The Gift Membership is for a one-time use only. The purchasing or redemption of the Gift Membership may not be combined with any other offers, coupons, discounts or promotions. The Gift Membership may not be exchanged or credited toward the purchase of any SATARANJI AFRICA Memberships.

Fraud and notice of non-payment

SATARANJI AFRICA reserves the right to refuse to honor a Gift Membership if SATARANJI AFRICA suspects that the Gift Membership was obtained fraudulently. SATARANJI AFRICA reserves the right to refuse to honor any Gift Membership in the event of a disputed credit card charge, bounced check or other failure of consideration.

Changes to Agreement

SATARANJI AFRICA reserves the right to modify, alter, change or amend this Agreement from time to time in its discretion without advance notice. The current version of this Agreement is available at SATARANJI AFRICA.

GIVEAWAYS POLICY

Effective date: 30/11/2024

From time to time, SATARANJI AFRICA sponsors any number of giveaways, games of chance, or sweepstakes events.

NO PURCHASE WILL BE NECESSARY TO ENTER OR WIN PRIZES OR MONEY FOR ANY EVENTS OF THIS NATURE. MAKING A PURCHASE OR PAYMENT OF ANY KIND WILL NOT INCREASE YOUR CHANCES OF WINNING. ALL SUCH EVENTS ARE VOID WHERE PROHIBITED OR RESTRICTED BY LAW.

By participating in such Events, you unconditionally accept and agree to comply with and abide by these Rules, any Official Event Rules related to the Event, and the decisions of SATARANJI AFRICA, which shall be final and binding in all respects. SATARANJI AFRICA will be responsible for the collection, submission or processing of Entries and the overall administration of such Events. Entrants should look solely to us for any questions, comments or problems you may have related to these Events.

ELIGIBILITY

All such Events will be open to legal residents of lawful age in locations where these Events are permitted. SATARANJI AFRICA, and its respective parents, subsidiaries, affiliates, distributors, retailers, sales representatives, advertising and promotion agencies, and each of our respective officers, directors and employees, are ineligible to enter the Sweepstakes or win a prize.

Household Members and Immediate Family Members of such individuals are also not eligible to enter or win. “Household Members” shall mean those people who share the same residence at least three months a year. “Immediate Family Members” shall mean parents, step-parents, legal guardians, children, step-children, siblings, step-siblings, or spouses. These Events are subject to all applicable federal, state and local laws and regulations and are void where prohibited or restricted by law.

PRIZES

SATARANJI AFRICA will determine and announce the available Prizes for any such Event in due course. Only one prize per person and per household will be awarded. Gift cards and gift certificates are subject to the terms and conditions of the issuer. Prizes cannot be transferred, redeemed for cash or substituted by winner. We reserve the right in our sole and absolute discretion to award a substitute prize of equal or greater value if a prize described in the Official Rules is unavailable or cannot be awarded, in whole or in part, for any reason. The approximate retail value (ARV) of the prize will represent our good faith determination. That determination is final and binding and cannot be appealed. If the actual value of the prize turns out to be less than the stated ARV, the difference will not be awarded in cash. We make no representation or warranty concerning the appearance, safety or performance of any prize awarded. Restrictions, conditions, and limitations may apply. We will not replace any lost or stolen prize items.

These Events are open to legal residents of eligible locations and Prizes only will be awarded and/or delivered to addresses within said locations. All federal, state and/or local taxes, fees, and surcharges are the sole responsibility of the prize winner. Failure to comply with the Official Rules will result in forfeiture of the prize.

HOW TO ENTER

You may enter any such Event during the Promotion Period online by visiting the applicable entry form, which will be made available on our website.

Automated or robotic Entries submitted by individuals or organizations will be disqualified. Internet entry must be made by the Entrant. Any attempt by Entrant to obtain more than the stated number of Entries by using multiple/different email addresses, identities, registrations, logins or any other methods, including, but not limited to, commercial contest/sweepstakes subscription notification and/or entering services, will void Entrant’s Entries and that Entrant may be disqualified. Final eligibility for the award of any prize is subject to eligibility verification as set forth below. All Entries must be posted by the end of the Promotion Period in order to participate. Our database clock will be the official timekeeper for all such Events.

WINNER DETERMINATION OR SELECTION

The Winner(s) of such Event will be determined or selected in the manner described in the Official Rules for the applicable Event.

WINNER NOTIFICATION

Winner will be notified by email at the email address provided in the Entry Information with the timeframe announced in the Official Event Rules for the applicable Event. Potential Winner must accept a prize by email as directed by SATARANJI AFRICA within the timeframe announced in the Official Event Rules for the applicable Event. We will not be responsible for any delay or failure to receive notification for any reason, including inactive email account(s), technical difficulties associated therewith, or Winner’s failure to adequately monitor any email account.

Any winner notification not responded to or returned as undeliverable may result in prize forfeiture. The potential prize winner may be required to sign and return an affidavit of eligibility and release of liability, and a Publicity Release (collectively “the Prize Claim Documents”). No substitution or transfer of a prize is permitted except by SATARANJI AFRICA.

PRIVACY

Any personal information supplied by you will be subject to our privacy policy at SATARANJI AFRICA. By entering any such Event, you grant to SATARANJI AFRICA permission to share your email address and any other personally identifiable information with third party Event partners for the sole purpose of administration and prize fulfillment. SATARANJI AFRICA will not share your email address or any other personally identifiable information with the public. We may, however, make a list of Winners’ usernames publicly available and Winners’ real names available only upon request.

LIKENESS AND CONSENT

You agree that we may use your name, image and likeness for advertising, publicity and promotional purposes in any and all media without compensation (unless prohibited by law) or additional consents from you or any third party and without prior notice and you agree to execute specific consent to such use if requested by us.

LIMITATION OF LIABILITY

SATARANJI AFRICA assumes no responsibility or liability for: (a) any incorrect or inaccurate entry information, or for any faulty or failed electronic data transmissions; (b) any unauthorized access to, or theft, destruction or alteration of entries at any point in the operation of this Event;

(c) any technical malfunction, failure, error, omission, interruption, deletion, defect, delay in operation or communications line failure, regardless of cause, with regard to any equipment, systems, networks, lines, satellites, servers, camera, computers or providers utilized in any aspect of the operation of the Event; (d) inaccessibility or unavailability of any network or wireless service, the Internet or website or any combination thereof; (e) suspended or discontinued Internet, wireless or landline phone service; or (f) any injury or damage to Entrant’s or to any other person’s computer or mobile device which may be related to or resulting from any attempt to participate in the Event or download of any materials in the Event.

If, for any reason, the Event is not capable of running as planned for reasons which may include without limitation, infection by computer virus, tampering, unauthorized intervention, fraud, technical failures, or any other causes which may corrupt or affect the administration, security, fairness, integrity or proper conduct of this Event, SATARANJI AFRICA reserves the right at its sole discretion to cancel, terminate, modify or suspend the Event in whole or in part. In such event, we shall immediately suspend all drawings and prize awards, and we reserve the right to award any remaining prizes (up to the total ARV as set forth in the applicable Official Event Rules) in a manner deemed fair and equitable by us. SATARANJI AFRICA and the Released Parties shall not have any further liability to any participant in connection with the applicable Event.

SOCIAL NETWORK OR EMAIL ACCOUNT PROVIDER DISCLAIMER

An email account may be required to enter. If you don’t already have an email account, you will need to visit an email account provider and then create an email account. It generally is free to create an email account. Any SATARANJI AFRICA Event promotion of this nature is in no way sponsored, endorsed or administered by, or associated with any email account provider. You understand that you are providing your information to the SATARANJI AFRICA and not to your email account provider. By participating via your email account provider, you also may be subject to your email account provider’s data policy and terms of use, which can be found on their platform.

WINNER LIST/OFFICIAL RULES

To obtain a copy of the applicable Winner List with real names or a copy of the Official Rules for the applicable Event, send your request along with a stamped, self-addressed envelope to:

SATARANJI AFRICA 50533-00100

Nairobi, Kenya

Requests for the real names of the winners must be received no later than the date set forth in the applicable Official Event Rules. For accessing a Winner List online, visit the URL for the applicable Event. The winner list will be posted after winner confirmation is complete.