1. WHO WE ARE

1.1  This Privacy Policy explains how [Kerma Games LLC, a limited liability company organised under the laws of the State of Delaware, United States, with registered office at 251 LITTLE FALLS DR, WILMINGTON, DELAWARE, 19808, USA]. (“Kerma”, “we”, “us”, “our”) collects, uses, shares and protects personal data of individuals who visit the campaign page for THE NEXT EPISODE by Kerma – Make Snoop's Birthday 2027 in LA (the “Campaign”), submit a contact/lead form, or participate in a Campaign activation (each a “Data Subject”, “you”).

1.2  This Policy applies specifically to the Campaign webpage(s) and related activations. It does not cover other Kerma websites, products or services, which are governed by their own privacy notices.

1.3  For questions about this Policy or to exercise your rights, contact our privacy team at privacy@kermagames.com. [If required: Kerma's EU representative under Art. 27 GDPR is 251 LITTLE FALLS DR, WILMINGTON, DELAWARE, 19808, USA.]

2. PERSONAL DATA WE COLLECT

2.1  We collect personal data you provide directly to us, namely:

(a)  Contact and lead form data: full name, business email, phone number, company/organisation name, job title, and any message or enquiry details you submit through a contact, sign-up or demo-request form on the Campaign page.

(b)  Campaign and promotional-activity data: if you or your organisation participates in a Campaign activation, are selected as an Operator, or are awarded or nominated for a Golden Ticket or Invitation, we (or your nominating organisation) may collect your full legal name, date of birth, nationality, passport/ID details, employer, role, contact details, and information relating to identity verification, security screening and, for confirmed guests, travel logistics necessary to organise the Event. This data is described in full in the Campaign Terms & Conditions.

2.2  We also collect limited technical data automatically when you visit the Campaign page, such as IP address, browser type, device information, pages viewed and referral source, generally through cookies and similar technologies (see Section 6).

2.3  We do not knowingly collect personal data from individuals under 18. The Campaign and its activations are directed at industry professionals and gaming operators who are at least 18 years of age, consistent with the Campaign Terms & Conditions.

3. HOW AND WHY WE USE YOUR DATA

3.1  We use personal data for the following purposes:

(a)  to respond to enquiries submitted via contact/lead forms and to follow up on business relationships (legal basis: legitimate interests in managing business communications; or steps prior to entering a contract);

(b)  to administer the Campaign, including verifying eligibility, running activations, selecting Operators and Golden Ticket recipients, and managing nominations and substitutions (legal basis: performance of the Campaign Terms as a contract with participants, and/or legitimate interests in operating the Campaign);

(c)  to verify identity, conduct security screening, and arrange venue access for the Event (legal basis: legitimate interests in Event safety and security, and compliance with legal obligations);

(d)  to send Campaign-related updates and, where you have consented or as otherwise permitted by law, promotional/marketing communications about Kerma's products and services (legal basis: consent, or legitimate interests for existing business contacts, subject to opt-out);

(e)  to comply with applicable law, including anti-bribery, anti-money-laundering, sanctions and gaming-regulatory obligations; and

(f)  to protect the rights, property and safety of Kerma, participants, guests and third parties, including detecting and preventing fraud.

4. WHO WE SHARE YOUR DATA WITH

4.1  We may share personal data with:

(a)  Kerma affiliates and group companies, for the purposes described in Section 3;

(b)  service providers acting on our behalf, including event organisers, venue operators, security and identity-verification providers, travel coordination vendors, email/CRM platforms and IT hosting providers, each bound by contractual confidentiality and data protection obligations;

(c)  the Operator or industry organisation that nominated you, where you are a plus-one or nominated representative, to the extent necessary to manage your nomination and attendance;

(d)  regulators, law enforcement or other authorities where required by law or to protect Kerma's legal rights; and

(e)  a successor entity in the event of a merger, acquisition or sale of assets, subject to equivalent protections.

4.2  We do not sell personal data. Where required by applicable US state law, we will identify any "sharing" for cross-context behavioural advertising (see Section 8) and provide the required opt-out.

4.3  SBC Events Limited, SBC Summit Lisbon and their organisers/affiliates do not receive personal data from us in connection with the Campaign, consistent with the non-affiliation disclaimer in the Campaign Terms & Conditions.

5. INTERNATIONAL DATA TRANSFERS

5.1  Kerma is based in the United States, and the Event will take place in Los Angeles, California. If you are located in the European Economic Area, the United Kingdom or elsewhere outside the United States, your personal data will be transferred to, and processed in, the United States and potentially other countries where our service providers operate.

5.2  Where such transfers occur, we rely on appropriate safeguards required by applicable law, such as the European Commission's Standard Contractual Clauses (and the UK International Data Transfer Addendum, as applicable), or another valid transfer mechanism. You may request a copy of the relevant safeguard by contacting us using the details in Section 1.3.

6. COOKIES AND SIMILAR TECHNOLOGIES

6.1  The Campaign page may use cookies and similar technologies to operate the page, remember your preferences, and understand how visitors use it (analytics), and, where applicable, for marketing purposes.

6.2  We currently do not operate a cookie consent management platform on this page. Where required by applicable law (including the EU/UK ePrivacy rules), we will not set non-essential cookies until you have given consent, and we will provide a mechanism for you to accept, reject or manage cookie categories before such cookies are deployed. Essential cookies necessary for the page to function do not require consent.

6.3  You can also control cookies through your browser settings, though blocking some cookies may affect the functionality of the page.

7. DATA RETENTION

7.1  We retain personal data submitted via contact/lead forms for as long as necessary to respond to and manage the relevant business relationship, and thereafter in accordance with our standard records-retention practices.

7.2  We retain Campaign and activation-related personal data (including Operator, Golden Ticket and guest information) for the duration of the Campaign Period and the Event, and for a reasonable period afterward to comply with legal, tax, accounting, insurance and dispute-resolution obligations, after which it is securely deleted or anonymised.

8. YOUR PRIVACY RIGHTS

8.1  Subject to applicable law, you may have the right to: access the personal data we hold about you; request correction of inaccurate data; request deletion; object to or restrict certain processing; request data portability; and withdraw consent at any time where processing is based on consent (without affecting the lawfulness of processing before withdrawal).

8.2  If you are a California (or other applicable US state) resident, you may also have the right to know what personal information we collect, to request deletion or correction, and to opt out of "sale" or "sharing" of personal information (Kerma does not sell personal data) and out of certain profiling. We will not discriminate against you for exercising these rights.

8.3  To exercise any of these rights, contact us at marketing@kermagames.com. We may need to verify your identity before actioning a request. If you are in the EEA or UK, you also have the right to lodge a complaint with your local data protection authority.

9. SECURITY

9.1  We implement reasonable technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse or alteration. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. RELATIONSHIP TO THE CAMPAIGN TERMS & CONDITIONS

10.1  This Policy supplements, and should be read together with, the Campaign Terms & Conditions, including the provisions on privacy, promotional communications and image/video consent set out therein. In the event of any inconsistency regarding data processing, this Policy shall prevail.

11. CHANGES TO THIS POLICY

11.1  We may update this Policy from time to time to reflect changes in our practices or for legal, operational or regulatory reasons. The "Last updated" date at the top of this Policy indicates when it was last revised. Material changes will be notified as appropriate.

12. CONTACT US

12.1  If you have questions, concerns or requests regarding this Policy or our data practices, please contact us at marketing@kermagames.com or 251 LITTLE FALLS DR, WILMINGTON, DELAWARE, 19808, USA.