Legal

Privacy Policy

Last updated: December 1, 2024

Data Encrypted

All data encrypted in transit and at rest

No Selling Data

We never sell your personal information

Data Minimization

We only collect what we need

PIPEDA Compliant

Full compliance with Canadian privacy law

1. Introduction

Drazill Inc. ("Drazill," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our prediction market platform ("Platform"). This Policy applies to all users of our Platform, website, and related services. By using our Platform, you consent to the data practices described in this Policy. We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.

2. Information We Collect

We collect information in the following ways: **Information You Provide:** • Account registration details (name, email, date of birth) • Identity verification documents (government ID, proof of address) • Payment information (bank account, credit card details) • Communication preferences • Customer support inquiries **Information Collected Automatically:** • Device information (IP address, browser type, operating system) • Usage data (pages visited, features used, time spent) • Transaction history and trading activity • Cookies and similar tracking technologies **Information from Third Parties:** • Identity verification services • Payment processors • Analytics providers • Marketing partners (with your consent)

3. How We Use Your Information

We use your information for the following purposes: **Platform Operation:** • Create and manage your account • Process trades and transactions • Verify your identity and eligibility • Provide customer support **Legal Compliance:** • Comply with anti-money laundering regulations • Report to regulatory authorities as required • Prevent fraud and unauthorized access • Enforce our Terms of Service **Platform Improvement:** • Analyze usage patterns and trends • Develop new features and services • Personalize your experience • Conduct research and analysis **Communication:** • Send transaction confirmations • Provide market updates and alerts • Send marketing communications (with consent) • Respond to inquiries and requests

4. Information Sharing

We may share your information in the following circumstances: **Service Providers:** We share information with third-party vendors who assist us in operating the Platform, including: • Payment processors • Identity verification services • Cloud hosting providers • Analytics services • Customer support tools **Legal Requirements:** We may disclose information when required by law or in response to: • Court orders or legal process • Regulatory inquiries • Law enforcement requests • Protection of our rights **Business Transfers:** In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity. **With Your Consent:** We may share information for other purposes when you provide explicit consent. **We Never:** • Sell your personal information • Share your trading activity publicly without permission • Use your data for purposes unrelated to our services

5. Cookies and Tracking

We use cookies and similar technologies to: • Keep you logged in • Remember your preferences • Analyze Platform usage • Prevent fraud • Deliver relevant content **Types of Cookies:** • **Essential:** Required for Platform functionality • **Analytics:** Help us understand usage patterns • **Preferences:** Remember your settings • **Marketing:** Deliver relevant advertisements (with consent) **Your Choices:** You can control cookies through your browser settings. Note that disabling certain cookies may limit Platform functionality. We also use: • Local storage for session data • Pixel tags for email tracking • Analytics SDKs for usage data

6. Data Security

We implement robust security measures to protect your information: **Technical Safeguards:** • TLS encryption for all data in transit • AES-256 encryption for data at rest • Multi-factor authentication • Regular security audits and penetration testing • Intrusion detection systems **Organizational Safeguards:** • Limited access to personal information • Employee training on data protection • Incident response procedures • Vendor security assessments **Financial Data:** • PCI DSS compliance for payment processing • Segregated accounts for user funds • Regular third-party audits Despite our efforts, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security but will notify you of any breaches as required by law.

7. Data Retention

We retain your information for as long as necessary to: • Provide our services • Comply with legal obligations • Resolve disputes • Enforce our agreements **Retention Periods:** • Account information: 7 years after account closure • Transaction records: 7 years (regulatory requirement) • Identity verification: 7 years (AML requirement) • Support tickets: 3 years • Marketing data: Until consent withdrawn You may request deletion of your data subject to legal retention requirements.

8. Your Privacy Rights

Under Canadian privacy law, you have the right to: **Access:** Request a copy of your personal information we hold **Correction:** Request correction of inaccurate information **Deletion:** Request deletion of your information (subject to legal requirements) **Portability:** Receive your data in a portable format **Withdraw Consent:** Withdraw consent for certain processing activities **Opt-Out:** Unsubscribe from marketing communications **Complaint:** File a complaint with the Privacy Commissioner of Canada To exercise these rights, contact us at privacy@drazill.com. We will respond within 30 days.

9. Children's Privacy

Our Platform is not intended for individuals under the age of 19 (or the age of majority in your province/territory). We do not knowingly collect personal information from minors. If we become aware that we have collected information from a minor, we will take steps to delete it immediately. If you believe we have inadvertently collected information from a minor, please contact us at privacy@drazill.com.

10. International Data Transfers

Your information may be transferred to and processed in countries other than Canada, including the United States, where our service providers are located. When we transfer data internationally, we ensure appropriate safeguards are in place: • Standard contractual clauses • Adequacy decisions • Binding corporate rules We ensure that any international transfers comply with applicable privacy laws and provide adequate protection for your information.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by: • Posting the updated Policy on this page • Updating the "Last Updated" date • Sending an email notification for significant changes • Displaying a notice on the Platform Your continued use of the Platform after changes become effective constitutes acceptance of the updated Policy.

12. Contact Us

For privacy-related inquiries or to exercise your rights, contact our Privacy Officer: Drazill Inc. Attn: Privacy Officer 100 King Street West, Suite 4700 Toronto, ON M5X 1C9 Canada Email: privacy@drazill.com Phone: 1-888-DRAZILL We will respond to all inquiries within 30 days.