Privacy Policy

1) GLOSSARY

Privacy Policy: This written notice describes the policies by which www.gana777.sv (the "Site") informs customers and the general public about how personal data of the owners and those to which the Site has access are handled.

Content: Text, images, videos, audio clips, software, and any other type of information that can be generated, provided, or found on or through the Site.

Personal Data: Also referred to as "Personal Information." Any information relating to an identified or identifiable individual.

DSensitive Personal Data: Personal data that refers to the most intimate information of its owner, which, when misused, can generate discrimination or risk to its owner. In particular, it will be considered confidential when it can reveal aspects such as racial or ethnic origin, present and future health status, genetic information, religious, philosophical, and moral beliefs, trade union affiliation, political opinion, and sexual preferences.

Site Parties: Affiliates, headquarters offices and successors, as well as each of their employees, beneficiaries, staff members, advisors, agents, and directors of the Site.

Services: The services that the Site makes available to Users through the Site.

Site: Website www.gana777.sv and its mobile application.

www.gana777.sv: Also referred to as "we," we are SBET, S.A. de C.V., an Authorized Permit Holder issued by the Lotería Nacional de Beneficencia, with Permit No. SJD-ME-003/2025, dated February 14, 2025 in service provision contract for non-exclusive access to the computer platform www.gana777.sv.

Terms and Conditions: The terms and conditions that establish rights and obligations to which the user or unregistered visitor has access or must comply to be able to access the Site.

User: Also referred to as "You" or "Owner." Any person who has provided the requested information on the Site to access it, therefore, the rights and obligations established in the Terms and Conditions may be different from those of an unregistered visitor.

Unregistered Visitor: Also referred to as "You." Any person who does not have the status of a user but may have limited access to the Site without having provided the necessary information to be considered a user.

2) SITE PRIVACY POLICY:

Protecting your privacy, including your personal data, is important to us. We are committed to maintaining your trust and protecting your personal information.

This Privacy Policy describes how the Site's management team and its affiliates ("we") collect, use, and disclose your personal information in relation to the Site.

Please read this Policy carefully before using our Services. You should not use our Services if you are not comfortable with all or some of the provisions set forth below. Your continued use of our Services constitutes your consent to this Policy and the use and disclosure of your personal data and other similar information as set forth herein.

Consent.

Considering that by accessing the Site, the Owner has access to this Privacy Policy, hereby: (a) acknowledges this Privacy Policy; (b) grants consent for the handling of their personal data; (c) expressly acknowledges and agrees that the Site or the Site Parties may transfer personal data in accordance with these Terms and Conditions.

The Site will require separate express consent from you to use personal financial and banking information, as well as sensitive personal data. However, this may not be the case if the Site is required by a court order or an official mandate from a competent authority to do so.

If this is the case, the Site will inform you about the corresponding act of authority that requires us to disclose information.

Collected Personal Information.

We collect different types of personal data that are related to the Services offered by the Site, specifically:

Information provided directly by you.
Information obtained from your device(s) and the use of our Services, including cookies, web beacons, and other internet technologies.
Information provided by third parties.

Personal information provided directly by you.

We collect various types of information and content that you directly provide to us. In order to register as a member or to access some of our Services, you will be asked to provide us with certain personal information such as your name, phone number, email address, physical address, as well as certain banking information. We also collect other types of content and information, including any information that you may add to your member account and any other community profile, photographs, or any other information or documents that you submit or provide, as well as communications transmitted through our networks.

We collect payment and billing information provided when you access some of our Services or when you purchase products or services. If you do not provide us with the requested information, we may not be able to provide the Services in their entirety.

To the extent that you disclose any other personal information of other individuals, we assume that you have authorization from such individuals for the disclosure of their personal information, as well as its handling in accordance with the terms of the provisions set forth in this Privacy Policy.

Information from your device(s) and Service usage.

We collect information about your use of our Services, and depending on the accessibility and permissions settings of your device, we may collect other types of information as indicated below, which comes from or is related to computers, mobile phones, and other devices on which you install or access our Services. We use standard internet technologies, such as cookies and web beacons, to gather information about your computer or device and your online activity, as explained in more detail in the cookie section.

The information we gather in this regard includes:

Browser type and operating system.
IP address and device identifiers.
Your browsing behavior on our Services, as well as the amount of time you spend accessing our Services online and the links you click within our online Services.
The websites you visit before or after our site.
Whether you opened or forwarded our emails or checked the offers or links we sent you.
Your general or specific geographic location through GPS, Bluetooth, or Wi-Fi signals, to the extent permitted by device settings.

If you use our internet connection, networks, telecommunications systems, or information processing systems, the Site may also monitor your activity and any other files or text at any time, in accordance with applicable law, to ensure compliance with the company's policy.

Information provided by third parties.

We may receive and/or collect information about you from publicly available and commercial sources and other third parties permitted by applicable law. We may combine this information with any other information we gather about you when necessary to provide the requested Services.

Information provided by minors.

To use our Services, you must be at least 18 years old and above the legal age for gambling in the jurisdiction where you reside. Therefore, we do not collect personal data from anyone under the age of 18.

Use and management of personal data.

We will use the personal data we collect for the following purposes when necessary:

Providing our products and Services. We will use your personal information to provide you with our products, Services, and requested features; to respond to inquiries we receive from you; to verify your identity and eligibility regarding any use of our Services; to send you notices and other operational communications, as well as for troubleshooting purposes; to fulfill obligations that may arise from any legal or business relationship generated by the Services provided.
Improving our Services and analyzing how users use and navigate through them.
Managing the efficiency of our Services.
Conducting audits and record-keeping for the use of local, state, or federal authorities, as well as performing accounting and administrative tasks to enforce or manage legal claims.
Issuing advertising and promotional materials, subject to any required legal consent, which, if necessary, will be obtained at the appropriate time. This includes the possibility of contacting you periodically with offers and information about our Services, benefits, and events; sending newsletters or any other type of information on topics of interest; conducting online surveys and promoting our Services, benefits, and events in any other way. We may also send you direct advertising, both within and outside of our Services.
For security reasons, to protect, enforce, or defend legal claims, the privacy, security, or property of our employees or the Site and its Parties, agents, or other individuals; to ensure compliance with Site policies and to comply with applicable laws and government requests.

Our Services may contain links to other sites for which we are not responsible. We provide these links to third-party sites for the convenience of our members or users.

They are not intended to endorse or refer to the Services provided. Our Services are subject to our privacy statements, notices, and/or the autonomous and independent provisions of each service, which we recommend you read carefully.

The collection, use, and disclosure of your personal information collected through your access to third-party links while using our Services will be subject to the privacy policies of third parties, not to this policy.

Disclosure of personal information.

We share your personal data under the strictest standards of care and in accordance with the circumstances set forth below and to the following parties:

A. Service providers. We maintain business relationships with third parties to provide a wide variety of Services on our behalf. This includes, but is not limited to, engaging service providers to host data and platforms, fulfill our Service requests and respond to your inquiries; send emails on our behalf; process card payments and other transactions, as well as analyze data to improve our Services. For these reasons, we may share your personal information with them for the purposes described in the "Use and Management of Personal Data" section. The Site is committed to performing the aforementioned actions with the utmost care, using the strictest confidentiality standards.

B. Authorities, government agencies, and any third party when legally required and as necessary to provide and protect our Services. This includes occasional sharing of your personal information by us and our service providers with law firms, auditors, advisors, the police, and courts of justice, solely to the extent necessary to:

Provide the Services in their entirety.
Comply with applicable law or respond to a legal process or any request for cooperation from any governmental entity or law enforcement agency.
Detect, suppress, or prevent fraud or verify and enforce the policies governing our Services, as permitted by law.
Protect the rights, property, or safety of the Site and its Parties or our affiliates, business partners, customers, or employees, as required by law.

A. Third parties related to a corporate transaction. We will share personal information with a buyer in the event that the Site and/or its Parties or its assets are transferred, in whole or in part, to a third party, such as in the case of a merger, reorganization, or bankruptcy liquidation, when necessary.

B. External partners, with your consent. From time to time, we may request your consent to share personal information with third parties so that they can provide you with special offers, promotional material, or other materials of interest.

Third parties providing content or functionality to our Services.

We also partner with the following categories of third parties to collect, analyze, and use some of the personal data described in this Policy:

Third parties providing features and functionality to the Services through plugins. Even if there is no click or interaction with the social network services or other plugins, they may collect information about you, such as your IP address and the pages you visit.
Advertising providers enable our advertisers to deliver advertising on our Services or on other sites, including targeted ads based on your online behavior, while analytics companies help us measure and evaluate the usage of our Services.
Other content providers may offer products and services related to our Services and may operate content, contests, or surveys related to them.

These third parties collect or receive certain information about the usage of our Services, including through cookies, web beacons, and internet technologies. Over time, this information may be aggregated or combined with information collected through different websites and online services.

Information security and personal data protection.

We have implemented various procedures to protect your information. Although we apply these measures to protect your information, no security program is infallible, and therefore, it is not possible to guarantee absolute security for your personal data or any type of information.

ARCO Rights: Procedure for granting and withdrawing consent for the handling of your personal data.

You, on your own behalf or through a legal representative, have the possibility to exercise ARCO Rights (Access, Rectification, Cancellation, and Opposition) regarding the handling of your personal data.

- Access: You can request the Site to inform you about what information we have and how we obtained it. You will be sent a copy or an email with such information.

- Rectification: You can inform the Site about any modification of any specific data or all data (such as name, email, phone number, address, etc.) in case they are incorrect, inaccurate, or have changed.

- Cancellation: You can request the Site to delete or cancel personal data that is no longer necessary or no longer serves the purposes for which it was collected. These data may be blocked afterward, which means they will be identified and reserved to prevent further handling.

- Opposition: You can object to the handling of your personal data.

The Site must handle your request with due care and within the first twenty (20) business days after the submission of your request.

The submission of the Form or any request for additional information can be directed to the address mentioned here, or by email to the account indicated in the contact section, in which the Owner will inform which ARCO right is being exercised, providing the following information:

- Owner's name and accreditation of the legal representative, if applicable.

- Owner's address and email to which we can provide a response to the request.

- Description of the personal data on which you intend to exercise any ARCO right.

- Any other element that facilitates the identification or location of personal data.

In order for the Site to properly handle your request, it is necessary for you or your legal representative (if applicable) to adequately prove your identity. For this purpose, the necessary sections of the Form must be completed. In the event that you or your legal representative fail to establish your identity or do not provide the requested information correctly, the Site will contact you, by phone or by email, within the next five business days after its submission to ask you to clarify such omission. If you do not respond to the aforementioned requirement, it will be understood that you do not wish to proceed with such request.

The Site will inform you of the resolution taken within no more than twenty (20) business days after the date on which your request was received, or the day after such request has been properly modified according to the Site's requirement. In all cases, the resolution will be communicated to you by email to the email address provided in the request.

The denial of the use of your Personal Information for the purposes described in this Privacy Policy will not constitute a reason for us to deny you our Services. Please note that if you revoke your consent to such handling, some Services may not be provided to you in their entirety.

It is possible to revoke the consent you have granted us if your personal data is not necessary for us to fulfill essential objectives. However, it is very important to note that your request regarding the non-use of your personal data may not be fully or immediately satisfied, as we may be required to continue handling your personal data to comply with legal requirements or contractual obligations.

Marketing rules.

If you choose to receive marketing emails from third parties, the Site will provide these third parties with your personal data so that they can contact you directly to offer their products and services that do not belong to the Site. If you later decide to stop receiving marketing emails from third parties, you will need to contact them directly or follow the instructions found at the bottom of their marketing emails.

Cookies, web beacons, and other internet technologies.

Both we and other third parties that provide content and other functionalities on our Services use cookies, web beacons, and similar internet technologies in our online Services.

Cookies.

A cookie is a small file that can be stored on your computer or other device. Companies use a cookie to recognize your device across different websites, services, devices, or browsing sessions.

Our Site may use Google Analytics, an analytics service provided by Google Inc. ("Google"). Google Analytics uses cookies, which are text files stored on a user's computer and allow the website to analyze how users navigate it.

The information generated by a cookie regarding the use of our websites is generally transmitted to and stored on a Google server in the United States. Google will use this information on behalf of the website operator to evaluate the use that users make of the Site, compile activity reports, and provide services related to activity on the Site and internet usage for the website provider.

The IP address transmitted by your device as part of Google Analytics will not be associated with any other data held by Google. You can refuse the use of cookies by selecting the appropriate settings on your browser, but please note that if you do this, you may not be able to use the full functionality of our Services.

Web Beacons and Other Internet Technologies.

We and third parties may also use web beacons (also known as clear GIFs, pixel tags, or web bugs) and other technologies to collect information about your use of our Services and interaction with emails and advertisements. Web beacons are small images embedded in web pages or emails that allow us or third parties to monitor your activity on our Services or assess the effectiveness of emails and advertisements. These technologies are used for various purposes, including analyzing and improving the Services, personalizing content and ads, and providing aggregate reporting to advertisers.

We strive to provide clear and transparent information about the use of cookies, web beacons, and other internet technologies on our Services. By continuing to use our Services, you consent to the use of these technologies as described in this Privacy Policy.

The browser within the framework of Google Analytics will not be associated with other Google data. It is possible to prevent the storage of cookies through your browser settings. However, please note that in this case, you may not be able to use all the features of our websites. Users can block the collection of data generated by cookies and related to their use on our websites (including their IP address) and their processing by Google by downloading and installing a browser add-on.

You can reject the use of cookies. When using a browser to access the Services, you can configure it to accept, reject, or receive notifications for all cookies sent. Click on the "Help" button in your browser for more information on how to change your cookie preferences. Please note that disabling all cookies may affect your ability to access and use certain tools of the Services.

Web Beacons.

Web beacons and other similar technologies are small snippets of code embedded in websites, advertisements, and emails that communicate with third parties. We use web beacons, including but not limited to, to know the number of people visiting a particular website, to install or communicate with cookies, and to understand usage patterns. We may also include web beacons in emails to determine if they have been opened, replied to, or forwarded.

Other Technologies.

There are other local storage and internet technologies, such as Local Shared Objects (also known as "Flash cookies") and HTML5 Local Storage, that function similarly to the cookies mentioned above. These technologies are installed on the device and can be used to store certain information related to your activities and preferences across different services and sessions. Please note that these technologies are different from cookies and you may not be able to control them using standard tools and settings from your browser.

How do we use these technologies?

Our websites use these technologies for the following purposes:

Manage our services.
Improve our services, which includes helping us measure and research the effectiveness of our content, features, ads, and other communications. This includes, but is not limited to, evaluating the websites and features our visitors have access to and how much time they spend on them. We may include web beacons in our email messages to determine if they have been opened, replied to, or forwarded.
Store login credentials and preferences so that you don't have to provide your credentials or references every time you log in to a Service.
Assist us and third parties in providing you with relevant content and advertising by collecting information about your use of our Services and other websites.

For more information on how we use the information we collect, please refer to the "Use and Handling of Personal Data" section.

Data Storage and Deletion.

When personal data is no longer necessary due to the expiration of the retention period for such personal data or for the fulfillment of the purpose for which the information was collected, and when there is no legal or regulatory provision stating otherwise, we will proceed to delete such personal data. If applicable law requires us to continue storing this personal information, we will transfer the information to an independent database or place it in a separate storage compartment.

In the case of electronic files, we will destroy those containing personal data through permanent deletion, making them irretrievable. We destroy other types of files, including paper documents, by shredding them.

Disclaimer of Warranties.

The use of the Site is at your own risk. The Site is provided "as is" and "as available." The Site does not warrant that (i) the site will meet your requirements, (ii) the site will be uninterrupted, timely, secure, or error-free, or (iii) the results that may be obtained from the use of the Site will be accurate or reliable as a whole.

Limitation of Liability.

You expressly understand and acknowledge that the Site shall not be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, including but not limited to damages for loss of business, use, data, or other intangible losses (even if the Site has been advised of the possibility of such damages), whether in contract, tort, negligence, strict liability, or otherwise, arising from: (i) the use or inability to use the Site or any other related information; (ii) unauthorized access or alteration of your transmissions or data; (iii) statements or conduct of third parties (including users) on the Site; or (iv) any other matter relating to the Site.

Some jurisdictions do not allow the exclusion of certain warranties or the limitation or exclusion of liability for incidental or consequential damages. Therefore, some of the limitations mentioned above may not apply to you. If you are not satisfied with any part of the Site or these Terms of Use, your sole and exclusive remedy is to stop using the Site.

Links to Other Websites.

Our website may contain links to other websites of interest. However, once you access these links and leave our site, you should note that we have no control over the other website. Therefore, we cannot be responsible for the protection and privacy of any information you provide while visiting those sites, and those sites are not governed by this Privacy Policy.

You should exercise caution and read the applicable Privacy Policy of that website.

Future Changes to this Privacy Policy.

Privacy rules and guidelines are part of a constantly changing environment that we protect as we continuously seek to improve our privacy practices and the management of personal data to provide a better experience in our Services.

The Site reserves the right to make changes to this Privacy Policy as necessary, in accordance with applicable law, internal policies, improvements to privacy practices and the management of personal data, or to better offer our Services.

You can find information about such opportunities on our Site, and in some cases, we will send an email to the address you provide.

Questions and Comments.

If you have any questions or comments about our Policy, please contact us.

Effective Date: February 14, 2025.

Last Updated: August 14, 2025.

Aiko and the Wind Spirit