**Arena Football Management, LLC Platform **(together with its affiliate companies/subsidiaries/components/services -“AFL,” “we,” “our” or “us”) recognizes the importance of maintaining the security of personal data that we collect. AFL Platform operates a website, a mobile application and related platform features available through its website ("Site") or its mobile application ("App"). This Privacy Policy applies to all AFL Platform services (the “Services).

The purpose of this policy is to inform you about the personally identifiable information we collect, how we use and share that information, how we protect that information, and the ways in which you can control how we use and share that information. By using our Site or our App, you agree to the terms of this policy and you expressly consent to the collection, use, and disclosure of your personal information in accordance with this policy. This policy does not apply to the practices of companies that AFL Platform does not own or control, or to individuals that AFL Platform does not employ or manage.

Specifically, this Privacy Policy describes our practices regarding –

Data Collection

Data Uses

Data Location & Retention

Data Sharing

Cookies & Tracking Technologies

Communications

Data Security

Data Subject Rights

Controller/Processor

Additional Notice & Contact Details

You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own discretion. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined in Section 4) as described below, please refrain from accessing, using or registering for our Services. If you are using the Services on behalf of a Merchant that is using the Services, we suggest that you contact the Merchant’s account administrator with any questions about the Service. You should also let the Merchant’s account administrator know if you do not want to be registered to the Services.

Data Collection

You may elect to provide a variety of information during your interactions with us and the Site and App, such as emails you may send us, ads you respond to, SMS or text messages that you may sign up for and emails or newsletters that you sign up to receive from us. We, or third parties acting on our behalf, receive data from you whenever you provide us with information.

User, or Buyer Data: Our Services enable Users and Merchants, or Buyers and Sellers to connect with each other more easily and to purchase or sell goods and services. AFL may request the following types of personal data relating to users –

Profile information (name, e-mail address, profile picture, social media wallet address)

Transaction details (digital and/or physical goods and services ordered or searched for, credit card details, bids relating to the sale of NFTs, wallet ID number for the crypto wallet, invoices and transaction history, GPS or mobile device location, additional details provided by the User with respect to their orders or searches, and any other information Users provide voluntarily);

Usage information (connectivity, technical and aggregated usage data and activity logs, log-in and log-out time, user agent, IP addresses, device and mobile app data [like type, OS, device ID, app version, browser version, locale, time-zone and language settings used], session recordings and analytics, and the cookies and pixels installed or utilized on their device; your interactions with other users’ content, such as shares, replies, if other users mention or tag you in content or if you mention or tag them, and broadcasts you’ve participated in (including your viewing history, listening, commenting, speaking, and reacting; how you interact with others on the platform, such as people you follow and people who follow you, including the contents of the messages, the recipients, and date and time of messages; if you communicate with us, such as through email, we will collect information about the communication and its content; and information on links you interact with across our services [including in our emails sent to you]).

Ratings and feedbacks (as submitted by the Buyer or User regarding Merchants or Sellers including chats, reviews and any other data submitted);

Merchant, or Seller Data: if you wish to use our Services as a Merchant – either independently or as part of a business account – or as a Seller you will need to open a User account before joining as a Merchant or a Seller. In such cases, we will collect the same type of information as the User or Buyer Data, and also the following types of personal data relating to Merchants and Sellers –

Business account information, as applicable (e.g. company name, address, phone number industry and opening hours); Banking information (as applicable: bank account details such as the name of the account holder, email address, date of birth, residence address, phone number, social security number [for U.S. residents] or other identifiable personal number [for non-US residents], routing number, recipient account number and any related information).

Admin Data: if you are an Admin facilitating the auctioning of NFTs, we will also collect the following types of personal data -

User Profile information (name, e-mail address, mobile phone number, location – city and country, saved addresses, picture and hashed password)

Usage information (connectivity, technical and aggregated usage data and activity logs, log-in and log-out time, user agent, IP addresses, device and mobile app data [like type, OS, device ID, app version, browser version, locale, time-zone and language settings used], session recordings and analytics, and the cookies and pixels installed or utilized on their device; your interactions with other users’ content, such as shares, replies, if other users mention or tag you in content or if you mention or tag them, and broadcasts you’ve participated in (including your viewing history, listening, commenting, speaking, and reacting; how you interact with others on the platform, such as people you follow and people who follow you, including the contents of the messages, the recipients, and date and time of messages; if you communicate with us, such as through email, we will collect information about the communication and its content; and information on links you interact with across our services [including in our emails sent to you]).

Ratings and feedbacks (as submitted by the Buyer or User regarding Merchants or Sellers including chats, reviews and any other data submitted);

Website Visitor, CRM & Prospect Data: We collect the following types of personal data concerning our website visitors, Users and Buyers, Merchants and Sellers, partners, investors and prospects-

Site usage information (connectivity, technical and aggregated usage data, such as User agent, IP addresses, device data (like type, OS, device ID, browser version, locale and language settings used), activity logs, session recordings, and the cookies and pixels installed or utilized on our Sites and/or their device);

Business account information (contact, contractual and billing details concerning our Merchants, which may also contain the details of their internal focal persons who directly engage with AFL on behalf of their organization, e.g., the account administrators, billing contacts and authorized signatories on behalf of the Merchant or partner; as well as details concerning their needs and preferences, as identified by us or recognized through our engagement with them);

Information concerning our prospects (contact and business details, our communications with such prospects (correspondences, call and video recordings, call transcripts, and analyses thereof), as well as any needs, preferences, attributes and insights relevant to our potential engagement)).

Communications Data (with Users, Merchants, prospects etc.): We collect direct interactions and communications with us (including recordings and transcripts of your calls, emails, form submissions and chats with us, e.g. for customer service, user enablement, feedback, support and training purposes or otherwise through LinkedIn, Facebook or Twitter.

We collect such data either automatically, through your interaction with us or with our Sites or Services; or through third-party services, social media, analytics tools, events we organize or participate in, and other business initiatives.

To the extent that any of the above-mentioned data only pertains to a non-human entity (e.g., the phone number or bank account of a company or business), we will not regard it as “personal data” and this Privacy Policy does not apply to it.

Data Uses We may use your User Registration Data and other information or data we receive or collect, as well as data we derive or infer from combinations of the foregoing, for a variety of purposes, including but not limited to:

The facilitation and performance of our Services, and creation and security of your account;

To comply with our legal and contractual obligations, and to support our legitimate interests in maintaining and improving our Services;

To verify your identity, authenticate your account, and defend against fraud, unauthorized use, and illegal activity. We also use the information to evaluate and affect the safety and quality of content on AFL Platform - this includes investigating and enforcing our policies and terms, as well as applicable law;

To provide and improve the Site and App and to develop new products and services; To send you information that you requested or agreed to receive;

To alert you to the latest developments and features on our Site and App and to notify you of administrative information, such as security or support and maintenance advisories; Providing customer service and technical support; and

Protecting and securing our Users, Merchants, partners, investors, ourselves, and our Services.

If you reside or are using the Services in a territory governed by privacy laws under which "consent" is the only or most appropriate legal basis for the processing of personal data (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by, or via the Services, e.g. ‘special categories’ under the GDPR), providing such personal data and using the Services, as well as your acceptance of our Terms and Conditions, our Acceptable Use Policy and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy. If you wish to revoke such consent, please contact us at [[email protected]]

Specifically, we use personal data for the following purposes:

To facilitate, operate, and provide our platform and Services;

To authenticate the identity of our Users and Buyers, Merchants and Sellers, and to allow them to access and use our Services;

To provide assistance and support to our Users and Buyers, Merchants and Sellers;

To share your data with our Service Providers (as defined in Section 4);

To gain a better understanding on how you use and interact with our Services, and how we could improve the User experience for you and others, and continue improving our products, offerings and the overall performance of our Services;

To contact you with general or personalized service-related messages, as well as promotional messages that may be of specific interest to you (as further described in Section 6 below);

To facilitate, sponsor and offer certain events, contests and promotions;

To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;

To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services, or for any other purpose; and

To comply with applicable laws and regulations.

We do not sell your personal information, including though not solely as defined under the California Consumer Privacy Act (CCPA). However, we may use your email address or other User Registration Data to provide you with technical support, send you notices about the Site and App or other promotional offers you have elected to receive, and to serve you with ads that are more relevant to your interests.

Data Location & Retention Data Location: Given the fact that AFL operates in many jurisdictions worldwide, your personal data may be maintained, processed and stored by us and our authorized Service Providers (defined below) in multiple locations, including in the United States, the EU and other jurisdictions, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.

While privacy laws may vary between jurisdictions, AFL and its Service Providers are each committed to protecting personal data in accordance with this Privacy Policy, reasonable and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred. For data transfers from the EU or UK we have entered into Standard Contractual Clauses. You can obtain a copy by contacting us as indicated in Section 10 below.

Data Retention: We will retain your personal data for as long as it is reasonably necessary for us to maintain and expand our relationship and provide you with our Services and offerings, in order to comply with our legal and contractual obligations, and to protect ourselves from any potential disputes (i.e. as required by laws applicable to financial solutions, log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our contractual terms and data retention policy.

Remember public content can exist elsewhere even after you remove it from AFL Platform. For example, search engines and other third parties may retain copies of your content longer, based upon their own privacy policies, even after they are deleted or expire.

Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by email at [[email protected]].

Data Sharing

Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data in response to a subpoena, search warrant or court order (or similar requirement,) and where such disclosure is necessary to comply with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our Services. We also reserve the right to preserve, use, share, or disclose your information if we believe that it is reasonably necessary to address fraud, security, or technical issues or

protect our rights or property, or the rights or property of those who use our services.

Service Providers: We engage selected third-party companies and individuals to perform services complementary to our own. Such Service Providers may provide hosting and server co-location services, communications and content delivery networks (CDNs), billing and payment processing services, data and cyber security services, fraud detection and prevention services, web and mobile analytics, e-mail, text messages and web/mobile notification distribution, monitoring and analytics services, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, call and session recording services, and our legal, financial and compliance advisors (collectively, “Service Providers“).

These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such limited purposes as determined in our agreements with them. Should you decide to directly engage with any of AFL’s Service Providers, please note that such engagement is beyond the scope of the terms applicable to your engagement with AFL, including this Privacy Policy, and will therefore be covered by the Service Provider’s terms and policies.

Our Service Providers shall be deemed as ‘processors’ in circumstances where AFL assumes the role of ‘controller’; and where AFL acts as the ‘processor’ for our Merchant, the Service Provider shall be deemed our ‘sub-processor’, as further described in Section 9 below.

Third Party Websites and Services: Our Services may also include links to third-party websites, and integrations with third party services (such as Wyre). Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are governed by such third party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such websites and third-party services.

Sharing Personal Data with our Merchants and their own Users: We may share your personal data with the Merchant owning the account to which you are subscribed as a User on behalf of such Merchant, including data and communications concerning your use of the Services or other interactions with us (but only in relation to that Merchant account). In such cases, sharing such data means that the account’s administrator(s) or other individuals that are part of the same Merchant account may access it on behalf of our Merchant, and will be able to monitor and review data such as orders, payments and collection of funds via our Services, as well as access any personal data that was submitted to the Services.

Sharing data between Users and Merchants: In order to provide our Services, we also share certain details about Users and Merchants with each other. This is required to connect between Users and Merchants based on preferences, location, or other parameters. For example, Users may search for specific goods or for Merchants in their proximity, after which they will be able to contact the relevant Merchant.

Sharing data between Buyers and Sellers of NFTs: In order to provide our Services, we also share certain details about Buyers and Sellers of NFTs with each other. This is required to facilitate the NFT marketplace, register bids for NFTs, enable Sellers to collect payment for NFTs purchased via the Services, and in order to connect between Buyer and Sellers based on preferences, location, or other parameters. For example, a Buyer may search for specific NFTs in relation to Sellers they follow, after which they will be able to contact the relevant Seller.

Protecting Rights and Safety: We may share your personal data with others if we believe in good faith that this will help protect the rights, property, or personal safety of AFL, any of our Users, partners or Merchants, or any members of the general public.

AFL Subsidiaries and Affiliated Companies: We may share personal data internally within our group of companies, for the purposes described in this Privacy Policy. In addition, should AFL or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, your personal data may be shared with the parties involved in such an event. If we believe that such change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

For the avoidance of doubt, AFL may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and/or anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.

Cookies & Tracking Technologies

Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies.” Some last for longer periods and called “Persistent Cookies.” We use both types.

We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the Services. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools.

Every browser allows you to manage your cookies preferences. Please bear in mind that disabling cookies may complicate or even prevent you from using certain parts of features of the Services. However, the use of cookies may be subject to additional rules including your consent, as further explained in our Cookie Policy.

Please note that if you get a new computer or device, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.

Communications

Service Communications: We may send you notifications (through any of the means available to us, including by email or SMS) of changes or updates to our Services, billing issues, service changes, etc. However, please note that you will not be able to opt-out of receiving certain service communications which are integral to the operation of our Services and your use thereof (like billing notices).

Promotional Communications: We may also notify you about new features, additional offerings, better ways to use the Services, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., phone, SMS, mobile notifications or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive such promotional communications, you may notify AFL at any time by contacting us at [[email protected]], or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.

Data Security

We and our hosting services implement systems, applications and procedures to secure your personal data, and to reduce the risks of theft, damage, loss of data, or unauthorized access or use of personal data. These measures are aimed to provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

Data Subject Rights

If you wish to exercise your rights under any applicable law, such as the EU General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), to request access to, and rectification or erasure of your personal data held with AFL, or to restrict or object to such personal data’s processing, or to port such personal data or to exercise the right to equal services and prices (each to the extent available to you under the laws which apply to you), please contact us at [[email protected]]. If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or in the UK as applicable to you.

When you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to better understand the nature and scope of the data to which your request pertains. Such additional information will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 3 above. We may redact from the data which we will make available to you, any personal data or confidential information related to others.

You will have the ability to access and modify your User Data on your account, which you may do through the Settings section of our Site or App at any time. You have control through Settings on your Account and on your Profile to limit data we collect from you and how we use it. You can also download the information you have shared with the Site and App. Upon your registration of an account on the Site or App, you may elect to receive promotional, marketing, or other similar emails tailored to your interests. You may change this election at any time.

Additionally, you may also unsubscribe from any promotional, marketing, or other similar emails you receive. We will send you confirmation emails and other Site-related or App-related announcements when it is necessary to do so.

State Laws

Your personal information and its collection, use, sources, and sharing are described in this policy. Please see below for additional provisions, as required under the consumer privacy law of your state.

California Residents

Your rights under Cal. Civ. Code § 1798.83 (Shine the Light law): We only share personal information (as defined) with third parties for direct marketing purposes if you either specifically opt-in, or are offered the opportunity to opt-out and elect not to opt-out of such sharing at the time you provide personal information or when you choose to participate in a feature on the Site or on the App. If you do not opt-in or if you opt-out at that time, we will not share your personal information with that identified third party for direct marketing purposes. Your rights under Cal. Bus. & Prof. Code § 22575(b) ("Do Not Track" Browser Settings): You are entitled to know how we respond to "Do Not Track" browser settings. Like many other websites, we do not currently alter our practices when we receive Do Not Track signals as there is no

consensus among industry participants as to what "Do Not Track" means in this context. However, you have the option to opt-out of interest-based advertising. To find out more about "Do Not Track," you may wish to visit www.allaboutdnt.com/.

Your rights under the California Consumer Privacy Act of 2018 (CCPA): CCPA provides for certain disclosures about your rights and the personal information we collect, sell, and disclose for a business purpose. To view this information or exercise your rights under CCPA, visit [CCPA Privacy]{.underline} Policy for CA residents.

Nevada Residents

If you are a resident of Nevada, you may apply limits to the sale of certain personal information to third parties for resale or licensing purposes, subject to applicable law. We do not sell your personal information for such use. You are entitled to register your preference for limits on such sales in the future by sending an email to us with the subject line, "Nevada Do Not Sell Request" along with your first and last name, zip code, and whether you are a former or current accountholder or user. Your email address must match the email address on your account to process this request.

Controller/Processor

Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing personal data: the “controller” (or the “business” under the CCPA), who determines the purposes and means of processing; and the “data processor” (or the “service provider” under the CCPA), who processes the data on behalf of the controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

AFL is the “controller” of personal data pertaining to its Users, Buyers, Merchants, Sellers, investors, visitors and prospects, and assumes the responsibilities of a controller (solely to the extent applicable under law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data will assume the role of “processor”.

AFL is the “processor” of registration and deregistration data pertaining to business Merchants’ User accounts (solely to the extent that such data is shared by our Merchant during the onboarding process). In such instances, our Merchant shall be deemed the “controller” of such data, and AFL will process such data on the Merchant’s behalf, as its “processor”, in accordance with its reasonable instructions, subject to this Privacy Policy, and the commercial and data processing agreements executed between AFL and such Merchants (as applicable). AFL’s Service Providers shall then act as designated sub-processors in these instances.

AFL’s Merchant will be responsible for meeting any legal requirements applicable to controllers (such as obtaining their consent or establishing other legal basis for processing). In certain circumstances, when NFT auctions take place on a Partner's website, AFL will process Buyer and Seller data as a data processor on behalf of the Partner.

Additional Notices & Contact Details Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our applicable platforms. The amended version will be effective as of the date it is published. We will provide a 10-day prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services.

After such notice period, all amendments shall be deemed accepted by you.

External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Services for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to AFL’s Services.

Registration on the Site or on the App by anyone under 18 years of age is prohibited. In accordance with the Children's Online Privacy Protection Act (COPPA), we never knowingly collect or maintain information on our Site or App from those we know are under the age of 18, and no part of our website or App is structured to attract anyone under 18. Upon notice that we have collected information from children under the age of 18, we will take immediate steps for its removal. If you believe that we might have any such data, please contact us by e-mail

at [[email protected]].

Questions, concerns or complaints: If you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal data held with us, please contact us at: [ [email protected]]