PRIVACY NOTICE

1. INTRODUCTION

Everi Labs Inc. together with its subsidiaries (i.e. Everi Labs AB) (collectively referred to as “Everi”, “we”, or “us”), are responsible for the processing of your personal data as described in this Privacy Notice (“Notice”).

We are established in the United States and operate globally, with a subsidiary in the European Union. Our Services are available in both jurisdictions. Depending on where you are located, the relevant Everi entity will act as the controller of your personal data:

• If you are located in the European Economic Area (“EEA”), or the United Kingdom (“UK”), Everi Labs AB is the controller and subject to the EU General Data Protection Regulation (“EU GDPR”) and the UK General Data Protection Regulation (“UK GDPR”).
• If you are located outside these regions, Everi Labs Inc. will act as the controller under applicable U.S. privacy laws.

We understand that your privacy is important to you, and we want you to feel that you can trust Everi when we process your personal information. This Notice outlines how Everi collects, uses, transfers, or otherwise processes (collectively “process”) your personal data and is published with the aim to enable you to understand how we process your personal data, why we do so, and to inform you about your data protection rights.

We are responsible for and committed to processing the personal data in accordance with applicable data protection laws, including the EU General Data Protection Regulation 2016/679 (“GDPR") and applicable national legislation. You can get in touch with Everi using the contact details set out in section 10 below.

You have a right to information about how we process your personal data. We, therefore, encourage you to read this Notice in full. In light of the volume of information in this Notice, if you only want to access a particular section of this Notice, you can click on the relevant link below to jump to that section:

• 2. SCOPE
• 3. HOW WE COLLECT YOUR PERSONAL DATA
• 4. WHY AND HOW WE USE YOUR PERSONAL DATA
• 5. RETENTION OF YOUR PERSONAL DATA
• 6. RECIPIENTS OF PERSONAL DATA
• 7. TRANSFERS OF PERSONAL DATA
• 8. YOUR RIGHTS
• 9. CHANGES TO THIS NOTICE
• 10. CONTACT INFORMATION

2. SCOPE

In the course of our business activities, we process personal data, which includes any information that can identify you directly or indirectly. This Notice applies to the following categories of individuals with whom we interact:

• (i) You visit and interact with us through our website https://www.everilabs.com/ (the/our “Website”) or otherwise interact with us;
• (ii) We are in commercial dialogues with you when the organization that you represent is an existing or prospective client or business partner of ours;
• (iii) You participate in our events.

We also want to clarify that we do not collect any sensitive information such as data revealing racial or ethnic origin, health status, political opinions, religious or philosophical beliefs, or trade union membership.

This Notice does not apply where our services, as described on our Website, are used by our clients. In such cases, the relevant client is responsible for the processing and protection of your personal data. Their privacy practices may differ from those described here, and you should contact the relevant client directly for further information.

3. HOW WE COLLECT YOUR PERSONAL DATA

Most of the time, we collect your personal data directly from you, such as when you fill in a form on our Website, or when you otherwise interact with us, e.g. in events. However, we also collect your personal data from other sources, such as information that is publicly available, for example, information about you on your employer’s website or social media such as LinkedIn. In certain circumstances, personal data will be generated internally by our systems, such as internal reference numbers.

4. WHY AND HOW WE USE YOUR PERSONAL DATA

This section explains why we process your personal data, what types of data we process for each purpose, and the legal basis that allows us to do so. Our goal is to ensure you understand the reasons behind the processing and how this processing supports our business operations.

4.1 When you visit and interact with us through our Website

When you visit and interact with us through our Website, we process your personal data to respond to your inquiries regarding our services when you fill in relevant forms on our Website or when you contact us via other communication channels. The personal data we process includes business contact details such as your name, business email address, and business phone number, as well as job-related information such as your job title and the organization you represent, together with any additional information you include in your message or inquiry. We base this processing on our legitimate interest in responding to your inquiries about our business operations and communicating with you, and we only use your information in ways that are necessary and proportionate to provide the requested information or support.

4.2 To market our Services

We process your personal data to market our services to persons in key positions within organizations that we consider would be interested in our Services. The personal data we process includes business contact details such as your name, business email address, and business phone number, as well as job-related information such as your job title and the organization you represent. This information is relevant because it helps us ensure that our marketing efforts are directed toward professionals whose roles are connected to the services we offer. We base this processing on our legitimate interest in marketing our services or, where required by applicable national law, on your prior consent.

4.3 Client relationship management, agreements, and administrative processes

We process your personal data to manage our relationship with our clients which are the company you represent, which includes signing relevant agreements with Everi, handling day-to-day communications, and performing administrative tasks such as billing and invoicing. The personal data we process may include business contact details such as your name, business email address, and business phone number, job-related information such as your job title and the organization you represent, signature data, communication data, transaction data, and any other personal data that an agreement may contain. This information is necessary to ensure that agreements are properly executed, that our relationship with clients is maintained, and that we can comply with legal obligations such as bookkeeping laws. We base this processing on our legitimate interest in administering our client relationships and ensuring that relevant agreements are in place, as well as on our legal obligations for accounting and record-keeping.

4.4 Business partnerships

If you choose to become a referral or solution business partner, we process your personal data to identify relevant partnerships, enable you to become our business partner, sign relevant agreements such as partnership agreements, and administer our ongoing relationship and day-to-day operations. The personal data we process includes business contact details such as your name, business email address, and business phone number, job-related information such as your job title and the organization you represent, signature and communication data. This information is necessary to manage the partnership process effectively and maintain a professional relationship. We base this processing on our legitimate interest in reaching out to potential partners, administering our partnership, ensuring agreements are in place, and managing our relationship.

4.5 When you participate in our events

When you participate in our events, we process your personal data to manage your registration and participation, take photos or record sessions, and promote similar events, and contact you afterward to collect feedback and improve the quality of our activities. The personal data we process includes business contact details such as your name, business email address, and business phone number, communication data related to your registration and feedback, and photos and/or video recordings from the event. We base this processing on our legitimate interest in administering and arranging events, spreading brand awareness, and improving our events.

4.6 To enable us to comply with legal obligations and defend against legal claims

We process your personal data to comply with various legal obligations. This means that, in order to meet requirements under applicable laws, we may need to collect and store certain personal data. The categories of personal data processed for this purpose can vary depending on the specific requirements set out in legislation such as tax, accounting, or bookkeeping laws. We base this processing on our necessity to comply with legal obligations.

Furthermore, we may process your personal data to enable Everi to establish, exercise, or defend legal claims. Legal claims in this context are not limited to current legal proceedings but also includes actual or prospective court proceedings, obtaining legal advice, or establishing, exercising, or defending legal rights in any other way. For this purpose, we will process any personal data that may be relevant. We base this processing on our legitimate interest in being able to establish, exercise, and defend against legal claims according to applicable law.

4.7 Cookies and similar technologies

Our Website does not use cookies or similar technologies at this time. If we decide to use such technologies in the future, we will do so only with your prior consent and in accordance with applicable data protection laws. In that case, we will provide a separate cookie notice that will include detailed information about the types of cookies used, their purposes, and how you can manage your preferences.

5. RETENTION OF YOUR PERSONAL DATA

We retain the personal data we collect from you where we have an ongoing legitimate business need to do so (e.g., to provide you with information you have requested or to exercise or defend legal claims) to comply with applicable legal, tax, or accounting requirements. When we have no ongoing legitimate business need or legal reason to process your personal data, we will either delete or anonymise it.

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or to comply with legal, regulatory, or contractual requirements. More specifically:

• Personal data related to the management of client and partner relationship (including contact details and communication data) will generally be kept for the duration of the relationship and for a reasonable period thereafter to handle any follow-up matters.
• Personal data related to our marketing operations will be retained until you opt out of receiving marketing communications or until we determine that the data is no longer relevant for our legitimate interest in marketing our services.
• Personal data related to events that we organise (including registration details and feedback) will be kept for a limited period after the event to analyze and improve future activities. Photos and recordings may be retained longer for brand awareness unless you request removal.
• Personal data that we need to retain pursuant to our legal obligations (including transaction data and data required for bookkeeping) will be retained for the period required by applicable laws, such as tax and accounting regulations.
• Data relevant for legal claims will be retained for as long as necessary to establish, exercise, or defend legal rights.

6. RECIPIENTS OF PERSONAL DATA

We may disclose the personal data described above to the following categories of recipients:

• (a) Courts and similar judicial entities and/or authorities when required by law or to comply with legal obligations.
• (b) Our affiliates within the Everi group for internal administrative purposes and to deliver our Services.
• (c) Our business partners where necessary to manage partnerships.
• (d) Service providers that support our core operational activities, such as IT infrastructure, payment processing, and event management.
• (e) New owners in the event of a change of ownership of our business, provided that the new owners will only process personal data as set out in this Notice.

7. TRANSFERS OF PERSONAL DATA

If the processing of personal data by Everi entities established in the EU, either directly by us or through our service providers, involves transferring your personal data to countries outside the EU/EEA (“Third Countries”), we ensure that adequate safeguards are in place so that your personal data remains protected in accordance with this Notice and applicable data protection laws.

We implement one of the following measures:

• (a) Transfer to an adequate country: By transferring the personal data to a country that the European Commission has recognized as providing an adequate level of protection; or
• (b) Appropriate safeguards: By using a valid transfer mechanism, such as the standard contractual clauses (controller-to-controller or controller-to-processor) approved by the European Commission, for transfers to countries that do not have an adequacy decision.

8. YOUR RIGHTS

You have certain data protection rights in relation to how we process your personal data. You can contact us at any time at legal@everilabs.com to exercise your rights as set out below. Once we receive your request we will respond as promptly as possible and, in any event, within one month. Please note that, the following rights are not absolute and are subject to applicable limitations, exceptions, and exemption. Before taking any action, we may ask you to verify your identity to ensure your request is handled securely.

Right to access

You have the right to request access to and information about how we process your personal data. In addition, you may request a copy of the personal data we process about you. Please note that your request must not adversely affect the rights and freedoms of others, such as their right to privacy and confidentiality. In such cases, we may need to limit the information we disclose.

Right to rectification

You have the right to challenge the accuracy of your personal data at any time. Depending on the purpose of the processing, you may also request that your personal data be completed. Where relevant, we may ask you to provide an additional statement to clarify or complete the information.

Right to erasure

In certain circumstances, you have the right to request the deletion of your personal data (the “right to be forgotten”), for example when the data is no longer necessary for the purpose for which it was collected or we no longer have a legal basis to continue processing it.

Please note that there may be legal reasons why we may need to retain your personal data, such as to comply with a legal obligation to retain the data, to establish, exercise, or defend legal claims, or when there is another lawful basis for processing your personal data.

Right to object

You have the right to object to the processing of your personal data at any time. This means we must stop processing your data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms.

You have an absolute right to object to receiving marketing communications from us at any time.

Right to data portability

When our processing is based on your consent or on a contract with you, you have the right to receive the personal data that you have provided to us in a structured, commonly used, and machine-readable format and to transmit that data to another controller. Where technically feasible, you may also request that we transmit your personal data directly to another controller.

Right to withdraw consent

If we process your personal data based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent applies only to future processing and does not affect the lawfulness of processing carried out before consent was withdrawn.

Automated decision-making

We do not make decisions based solely on automated processing, including profiling, that would produce legal effects concerning you or otherwise significantly affect you.

Additional information for U.S. residents

If you are a resident of the United States, certain state privacy laws, such as the California Consumer Privacy Act (CCPA), may grant you additional rights regarding your personal data, in addition to those listed above (subject to applicable limitations, exceptions, and exemptions). These rights are not absolute, and we may decline a request where permitted by law:

• Right to opt-out of the sale of personal data
  You may have the right to opt out of the sale of your personal data to third parties. However, we do not sell your personal data as “sale” is traditionally understood (i.e., an exchange for money). Nor do we sell, rent, release, disclose, or transfer personal information to any third party for monetary or other valuable consideration.
• Right to non-discrimination
  You have the right to be free from discrimination for exercising your privacy rights under applicable law. We do not discriminate against individuals for exercising the rights granted to them under applicable law and relevant to our processing of personal data.

Right to Lodge a Complaint

For EU residents:

You have the right to lodge a complaint with the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY), which supervises the processing of personal data in Europe:

Contact details:

For U.S. residents:

You also have the right to submit a complaint about our processing of your personal data to the appropriate government regulator or authority in your jurisdiction (for example, your state’s Attorney General).

9. CHANGES TO THIS NOTICE

If we make changes to this Notice, we will notify you on our Website. You can see when this Notice was last updated by checking the “last updated” date displayed at the top of this Notice. Therefore, please review this Notice from time to time so that you are aware when any changes are made to this Notice. Significant changes to how we collect or process your personal data will be notified to you via email.

10. CONTACT INFORMATION

Our contact details for our US company is:

Our contact information for our EU subsidiary is: