Below, we will explain the details in regard to the processing of personal data in accordance with the regulations in effect regarding personal data protection.

Data Controller

The data controller is ZITRO IP SARL (hereinafter ¨ZITRO¨) with registered offices at 17 Boulevard Royal, L2449 (Luxembourg), and its e-mail is: [email protected].

ZITRO undertakes to maintain the confidentiality of the personal data that you have provided and adopt all the measures necessary in order to prevent their modification, loss and processing or un-authorized access in conformity with that established in the regulation in effect.

Aim

The sole aim of the process is to perform the activities of “Let’s Win Up!” for the purpose of improving the contents, services and operations thereof.

ZITRO shall only designate your personal data for the aim described. Should the information be used for a different aim, ZITRO shall request the prior consent of the owner of the personal data information.

Your data shall be maintained during the performance of the aforementioned tests on ¨Let’s Win Up!¨. Once those tests have been completed, your personal data will be kept blocked during the legal statutory periods and subsequently, your data will be destroyed.

Legality

The legal basis for the processing of your data is the consent with which you provide us upon the acceptance of this privacy policy.

Recipients

We inform you that your data shall not be transferred.

In the event that ZITRO decided to communicate your personal data, you will be explicitly informed of the purpose of the file, the data transferred and the name and address of the transferee in order that, if the case, you were to give your unequivocal consent in this regard.

Rights

At any time, you may withdraw your consent and exercise your rights of access, rectification, limitation, cancellation, portability and opposition with respect to your personal data by means of a written communication addressed to the headquarters of ZITRO or by sending an electronic mail to the following address [email protected].

Said communication shall include your name and last name, the nature of the request, your address for purposes of notice, the date, your signature and a photocopy of your National Identification Card or another valid document that identifies you. The exercise of these rights is gratuitous.

In the event that you have any conflict in regard to the protection of your personal data, you may submit a claim to the National Commission for Data Protection, located at 1, avenue du Rock’n’Roll, L-4361 Esch-sur-Alzette, Luxembourg.