Client Privacy Policy

Effective: May 15, 2026
Version: 1.0

1. INTRODUCTION

Welcome to Jarvisheart

At Jarvisheart Limited (hereinafter – “Jarvisheart,” “We,” “Us,” or “Our”),
we prioritize your privacy and are dedicated to protecting your personal information.
This Privacy Policy outlines how we collect, use, share, and safeguard client personal data
in compliance with relevant data protection laws, such as the General Data Protection Regulation (GDPR).

This Privacy Policy (“Policy”) outlines how we collect, use, share, and safeguard personal data
when using our products and services (“Service” or collectively “Services”).
This Policy applies to our customers, partners, and end-users.
It does not cover our current and former employees, candidates, and website visitors.

Data Processing Roles

Data Controller: When you sign up for our products and Services,
Jarvisheart acts as the data controller of your personal data.
We process this data to deliver our services, communicate relevant content,
and enhance and promote our offerings.

Data Processor: When our customers use our products and Services,
Jarvisheart acts as a data processor (or service provider) of personal data on behalf
of these customers, who are the data controllers, in line with the Jarvisheart Data Processing Agreement.

2. WHO WE ARE

Jarvisheart Limited, registered at 1sts Apriliou, 2, Ergates, 2643, Nicosia, Cyprus,
is an iGaming development company dedicated to developing and delivering iGaming content
and products to the B2C operators and aggregators.

3. WHAT INFORMATION WE COLLECT AND PROCESS

3.1. Information you provide (B2B Contact Data)

• Account Information: Names, business email addresses,
  job titles, and telephone numbers of authorized personnel.
• Identity & Compliance: For “Know Your Business” (KYB) due diligence,
  we may collect documentation regarding company directors or ultimate beneficial owners (UBOs)
  as required by licensing authorities (e.g., Anjouan Gaming License).
• Payment Information: Corporate billing addresses and bank details
  for royalty payments or integration fees.
  We do not store full credit card details.

3.2. Technical Information

When your systems connect to our API/RGS, we log:

• API Usage Data: IP addresses of the Operator’s servers,
  request timestamps, and authentication tokens.
• Game Performance Data: Aggregated metrics on game rounds,
  load times, and error rates to ensure service stability.

3.3. Information processed on behalf of Clients (End-User Data)

Via the API, Jarvisheart processes pseudonymized End-User data
(e.g., a unique Player ID provided by the Operator, currency, bet amounts, and game outcomes).
This type of processing is covered by the Jarvisheart Data Processing Agreement.

Note: We do not collect “Real World” identities
(Names, Physical Addresses) of players.
The Operator remains the Controller of that data.

4. HOW WE USE YOUR INFORMATION

5. HOW WE SHARE PERSONAL DATA

5.1. Service Providers

We may share Personal Data with our third-party service providers
to support our websites, products, and services.
For example, we use service providers for data hosting,
sales support, customer support,
KYC/KYB procedures, analytics, reporting,
troubleshooting, and payment processing.

These service providers are prohibited from using your Personal Data
except for these purposes and are required to maintain confidentiality.

5.2. Marketing Communications

We may share limited personal data
(e.g., email addresses and engagement data)
with trusted third-party marketing partners
to deliver updates, promotions, and relevant communications.

You may opt out of marketing communications at any time
by using the unsubscribe link or contacting us directly.

5.3. Legal Disclaimer

We may disclose information where required by law,
including compliance with court orders,
legal obligations, fraud investigations,
or lawful government requests.

5.4. Corporate Transactions

If Jarvisheart undergoes a merger, acquisition,
or asset sale, your information may be transferred as part of that transaction.
We will notify you of any material changes.

6. HOW WE TRANSFER PERSONAL DATA INTERNATIONALLY

For transfers from the European Economic Area (EEA),
Switzerland, or the United Kingdom (UK),
we utilize Standard Contractual Clauses (SCCs)
and supplementary technical safeguards,
including encryption, TLS, and WAF protection.

7. HOW WE STORE AND SECURE PERSONAL DATA

7.1. Data Storage and Security

We implement industry-standard security measures,
including TLS encryption and restricted access controls,
to protect your personal information.

Credit card information is transmitted directly
to payment processors and is not stored on our servers.

If you have any questions about data security,
contact us at:
[email protected]

7.2. Retention of Personal Data

Financial and transactional information is retained for seven (7) years
to comply with legal and accounting obligations.

We retain Personal Data only as long as necessary
for legitimate business purposes or legal obligations.
Once no longer required, the data is securely deleted or anonymized.

8. YOUR PRIVACY RIGHTS

Under GDPR, you may have the following rights:

• Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to object or withdraw consent

We may verify your identity before processing requests
related to your personal data.

9. CHILDREN’S ONLINE PRIVACY

Our services are not intended for individuals under the age of 18,
and we do not knowingly collect personal information from minors.

10. USE OF AUTOMATED DECISION-MAKING TOOL

Jarvisheart does not engage in automated decision-making
that produces legal or similarly significant effects
under Article 22 GDPR.

11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time.
Updated versions will be posted on this page
with a revised Effective Date.

12. HOW TO CONTACT US

If you have questions regarding this Privacy Policy
or our handling of personal data,
please contact:

Jarvisheart Limited
Email:
[email protected]