Terms And Conditions

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Terms and conditions

for the publication of information content, the comparison of odds and commercial offers on remote

gaming

The purpose of this document is to regulate the terms and conditions of the assignment of the suppliers referred to

below. By registering on the site shown below, the Supplier accepts in full, without exclusions, these terms and

conditions as better defined. The stipulation of the " Contract for the services of publication of information content,

the comparison of odds and commercial offers on Remote Games " will be dealt with by the parties separately.

Given the abovementioned, MAC Srl unipersonale is a Concessionaire holder of the GAD concession n°15432 for

the exercise of Remote Gaming (“ GAD ”) pursuant to art. 24, paragraph 22, of Law 7 July 2009 n. 88 assigned by

the Customs and Monopolies Agency ("ADM ") and for the exercise of this activity it makes use of a specific remote

collection channel which it makes available to its users for participation in Remote Gaming after signing the

Contract drafted in compliance with the provisions of the ADM.

The Supplier is an operator specialized in the dissemination of information content exclusively through online

channels, mainly concerning games and sporting competitions. The Supplier declares to be in possession of the

necessary technical and professional skills as well as at least one suitable website, dedicated and already organized

for the purposes of carrying out the aforementioned information activity, (hereinafter the " Site "), within which are

placed available to users regulations and/or information regarding (i) the characteristics of the games offered by the

GAD concessionaires, (ii) the general conditions (iii) a comparison of the odds and/or commercial offers of the

various concessionaires as well as (iv) the prescriptions and provisions in force for the protection of lawful gaming

and for the promotion of safe, legal and responsible gaming, also in the implementation of specific ADM

institutional communication campaigns, pursuant to the provisions of art. 5, paragraph 2, lett. c), of the Concession

Agreement.

Whereas

(i) The Supplier declares its interest in carrying out the aforesaid information activity for visitors to the

Site also in favor of the Concessionaire, declaring that it is aware of the types of games offered by

the Concessionaire, as well as the relative characteristics, probability of winnings and commercial

offers in general;

(ii) The Supplier declares to have the technical knowledge and operational capacity to carry out the

activities covered by this contract concerning the information activities described above, in

compliance with the legislation of every source and degree applicable on the matter, including

Legislative Decree no. 231/2007 "Consolidated text of anti-money laundering regulations" and

subsequent amendments and additions and the circulars and regulations issued by the ADM or

various Authorities concerning, even indirectly, the object of this agreement;

(iii) The Supplier declares to be aware of the prohibition pursuant to art. 4 of Law no. 401/1989 and

subsequent amendments and additions, relating to the intermediation activity in the collection of

lawful gaming and, therefore, declares and undertakes to refrain from any activity that may be traced

back to intermediation in the collection of legal gaming;

(iv) The Supplier also declares that he is familiar with: - the current legislation on remote public gaming;

- the various prohibitions in force against citizens under the age of eighteen; - the regulations in force

concerning the prohibition of advertising of games and bets with cash winnings as well as gambling

envisaged by art. 9 Legislative Decree 12 June 2018 n. 87, converted with amendments by Law 9

August 2018, n. 96 (so-called Dignity Decree), as supplemented by the Guidelines issued by

AGCOM with resolution 132/19/CONS published on April 26, 2019.

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All of the above considered, MAC Srl has an interest in the information on the game offer being conveyed

independently by these suppliers through sites managed by the latter containing correct and up-to-date

technical/statistical information.

1. Scope

The main purpose is to regulate the information activity pursuant to and for the purposes of art. 5, paragraph 2, lett.

c), of the Concession Agreement, the Supplier undertakes to carry out information activities aimed at users

regarding:

(i) types and regulations of the games offered by the Concessionaire (e.g. titles);

(ii) the odds of winning;

(iii) the general conditions of the offer contained in the outline of the Gaming Account Contract offered

by the Concessionaire;

(iv) the odds and commercial offers regarding the various public games offered by the Concessionaire

(including odds for individual events, size and characteristics of bonuses, etc.),

all of this, also in the form of an information service and comparison with conditions and offers from the

Concessionaire's competitors, as well as the prescriptions and provisions in force for the protection of lawful gaming

and for the promotion of safe, legal and responsible gaming, also in the implementation of specific institutional

communication campaigns of the Customs and Monopolies Agency (ADM).

2. Services

The information activities may be carried out exclusively using the IT tools and the information material expressly

authorized and/or supplied by the Concessionaire.

The Supplier undertakes to carry out the information activity by inserting, on its web communication channels, the

information contents indicated in the preceding article, available from time to time on the Dealer's website or

indicated by the same, undertaking to keep them constantly updated in order to provide its users with timely and

truthful information.

The Concessionaire, through its website, provides the Supplier and its users with information regarding the

functioning of the games, any bonuses and their methods of use.

The Licensee delivers the URL, Username and Password to the Supplier for logging into the back office which

allows the latter to monitor the performance deriving from its activity. The Supplier undertakes to keep the back

office access credentials strictly confidential.

The Supplier is free from any obligation or commitment of stability and/or continuity, the possibility of carrying

out activities of an informative nature for users of its web communication channels, on an occasional basis, being

left to its sole discretion.

The information activity covered by this contract is left to the exclusive initiative of the Supplier, without any

coordination or subordination constraint with the Dealer and at its own risk, furthermore being the mutual

understanding between the Parties that of not establishing any type of agency relationship, of mediation and/or

procurement.

The Concessionaire reserves the right to establish, at its sole discretion, whether the eventual registration of a new

user on the Concessionaire's website with activation of the gaming account may be accepted or not (e.g. also upon

the positive outcome of the regulatory due diligence activities foreseen).

The Licensee is free to modify the terms and conditions of this agreement at any time and at its own discretion,

which will be duly communicated to the Supplier in writing, even in the event of any changes to the current

legislation of any applicable order and degree. The changes will be effective immediately following the

communication, unless the Supplier does not exercise the right of withdrawal with 15 days’ notice, without charges

or costs to be borne by it.

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3. Obligations of the Supplier

The Supplier declares and guarantees that the web communication channels it uses are managed in its own and

exclusive name and that it is authorized to fully use them.

The Supplier undertakes to include on its web communication channels all the information material found on the

Dealer's website and/or indicated by the Dealer himself free of charge, without making any changes, except with

the latter's prior written consent.

The Supplier declares and guarantees to bear all costs and charges relating to the Site and/or other web

communication channels on which the information contents will be published.

The Supplier undertakes to keep its web communication channels functioning and in good condition and to notify

the Licensee in writing of substantial changes to the design and/or layout of the same.

The Supplier declares that he is not an employee, consultant, agent, director, supplier of the Licensee and that he

has no family relationship (eg spouse, child, Supplier, parent, brother/sister, cousin) with partners, representatives

and/or collaborators of the same.

4. Prohibitions and guarantees

The Supplier is prohibited from:

a. promote through its web communication channels material contrary to law and public order, including

sexually explicit materials, incitement to violence or discrimination on a racial, sexual, religious, ethnic or

disability basis. The Supplier also undertakes not to promote illegal activities through the same channels,

or activities that violate the intellectual property rights of the Dealer and/or third parties;

b. carry out any type of user registration, even on behalf of third parties, on authorized and unauthorized sites

where the GAD or any other form of the game is offered;

c. assist any user in any phase concerning the registration of users on authorized and unauthorized sites where

GAD or any other form of gaming is offered;

d. allow the opening of websites or parts thereof in the browsers of its users to allow direct access to game

services;

e. provide false information, alter the data provided to/by the Concessionaire, provide the same data to other

Concessionaires for public gaming;

f. carry out any form of movement of gaming accounts in favor of players, both directly and indirectly;

g. promote any website that resembles the Dealer's website in any way, whether in whole or in part, giving

the impression that the aforementioned websites are those of the Dealer. The same prohibition also applies

to software applications for mobile phones and tablets;

h. adopt behaviors in violation of laws and regulations on gaming and the electronic market;

i. carry out any form of direct or indirect promotion of the game with cash prizes, including the GAD managed

by the Concessionaire, as well as any game collection activity;

j. open and/or have a gaming account with the Concessionaire. This prohibition is extended to the legal

representatives, partners, employees and collaborators in general of the Supplier.

The Supplier is not granted any power of representation, since he may not stipulate contracts in the name and on

behalf of the Dealer, nor bind the latter in any way towards third parties. Any conclusion of Game Account

Agreements with users is performed solely and exclusively by the Licensee.

The Supplier declares and guarantees the following:

a. to be familiar with the regulations in force regarding public games with cash prizes such as, by way of

example but not limited to:

- The Law of 13 December 1989 n. 401 "Interventions in the clandestine gaming and betting sector

and protection of correctness in the conduct of sporting events" and subsequent amendments and additions;

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- The Decree Law of 13 September 2012 n. 158 "Urgent provisions to promote the development of

the country through a higher level of health protection" (so-called Balduzzi Decree) converted into law,

with amendments, by Law 08.11.2012, n. 189;

- The Decree-Law of 12 July 2018, n. 87, containing "Urgent provisions for the dignity of workers

and businesses", converted with amendments by law 9 August 2018, n. 96 (so-called Dignity Decree) which

prohibited any form of advertising, even indirect, relating to games or bets with cash winnings as well as

gambling, however, carried out and on any medium, including sporting, cultural or artistic events, television

or radio broadcasts, daily and periodical press, publications in general, billboards, IT, digital and telematic

channels, including social media;

- Resolution no. 132/19 of 18 April 2019 of the Italian Communications Authority (AGCOM)

published on 26 April 2019, by virtue of which the guidelines on the implementation methods of art. 9 of

the decree-law of 12 July 2018 n. 87 and reaffirmed the prohibition of any form of advertising, even indirect,

sponsorship, or communication with promotional content of the game with cash prizes;

b. that against them, or against their legal representatives, there are no convictions with final

judgment;

c. that in the event that, after the signing of this contract, the subjective requirements referred to in

point b above should cease to exist, he undertakes to promptly notify the Dealer in writing;

d. to be informed of the activities and functions assigned by ADM to the Concessionaire, as well as

of the characteristics of the service offered by the Concessionaire to its users.

In the event of loss by the Supplier of the subjective requirements referred to in point b above, the Dealer may

immediately terminate this contract pursuant to art. 1456 of the Civil Code

The Licensee may not be held responsible in any case for the contents that the Supplier will publish on the Site.

Otherwise, as well as for any fine, damage or charge in general directly or indirectly consequent to the contents

present on the Site and/or to the Site itself and charged or chargeable to the Licensee, the Supplier will be required

to keep the latter fully harmless and indemnified.

5. Obligations of the Concessionaire

The Licensee will be required, from time to time, to make available to the Supplier the data relating to the games,

odds and commercial offers available on its website. The Parties agree that the above information may also be made

available by publication on the Dealer's website.

6. Supplier Fees

For carrying out the activities covered by this contract, the Concessionaire will pay the Supplier an all-inclusive fee

equal to what is specified and under the conditions set out in the contract which will be subject to negotiation

between the Parties separately. The aforementioned remuneration will be recognized at the end of the month

following each reference accounting period corresponding to the calendar month (or to a different period that the

Concessionaire may indicate).

The remuneration will accrue exclusively with reference to the users/visitors of the Site who, on the basis of the

information content published therein, will reach the Concessionaire's site through the Site itself, subsequently

proceeding with the formalization of the gaming account contract and the activation of the account definitively.

7. Duration, modification, withdrawal and assignment of the contract

The contract will be valid for the entire duration of the concession agreement relating to the GAD in place between

the Concessionaire and ADM, including any extensions and/or renewals.

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Each of the Parties has the right to withdraw freely and without charge from this contract at its sole discretion, by

means of written communication to be sent to the other party with at least 7 (seven) days' notice.

In the event of revocation and/or forfeiture and/or termination of the Concession, the Contract shall be deemed

immediately terminated for all purposes.

In the event of withdrawal and/or termination of the contract for any reason, no compensation, indemnity or

reimbursement of any kind will be due to the Supplier, with the exception of fees accrued up to the effective date

of the contract, it being understood that, after the date of termination, the Supplier itself will not be able to claim

any rights regarding the activity carried out pursuant to the contract (including possible rights against gaming

account holders), expressly renouncing them.

The Supplier may not transfer this contract in any form (including the transfer of the business branch and/or shares

of the Supplier) without the prior written consent of the Dealer. Otherwise, the Concessionaire will have the right

to terminate the contract pursuant to art. 1456 of the Civil Code

In the event of a change of the owner/administrator of the Supplier's firm/company, the latter is required to inform

the Dealer in advance, who may in any case and in any case freely exercise his right of withdrawal.

The Supplier is also required to promptly inform the Licensee in the event of a change of the URL/domains of its

web communication channels, through which it carries out the information activity covered by this contract.

In the event of termination of this contract for any reason, the Supplier undertakes to:

a. immediately stop using the IT tools and information material, as well as the trademarks, logos

and/or other distinctive signs of the Concessionaire;

b. cease any information activity concerning the Concessionaire and/or its gaming collection

channel;

c. return to the Licensee all confidential information that he may have become aware of under this

contract, including all related copies in his possession, or to definitively destroy the same, promptly giving

proof of this to the Licensee.

8. Confidentiality and protection of personal data

For the entire duration of the relationship and for the 5 (five) years following its termination, whatever the cause,

each of the Parties undertakes for itself and, pursuant to Article 1381 of the Civil Code, also for its employees, if

any, consultants and collaborators:

a. to keep strictly confidential and not to divulge the facts, projects, documents, data and any other

information, of which it comes into possession and, in any case, becomes aware in relation to the

execution of this contract;

b. not to use the information described in the previous point for purposes other than those contemplated

in this contract, in whole or in part;

c. to take all appropriate precautions so that said information is not communicated to third parties or in

any case disseminated or made public.

The Parties mutually undertake to process the personal data of which they become aware in the execution of this

contract in compliance with the Privacy Code and its subsequent amendments as well as in compliance with the

European Regulation 2016/679 (so-called GDPR). To dispel any interpretative doubts, it should be noted that the

personal data relating to the holders of the gaming account are not visible to the Supplier.

In relation to the obligations pursuant to articles 13 and 14 of the Regulation referred to in this article, the

Concessionaire provides the Supplier with information relating to the processing of personal data, as per the

information contained in Annex 1 (Privacy Information).

9. Express termination clause

The parties may terminate the contractual relationship by law, pursuant to art. 1456 of the Civil Code, by simple

written communication, in the event of a breach by the Supplier of the obligations imposed on him, or pursuant to

art. 1353 of the Civil Code, in any case of termination of the concession relationship with the Concessionaire. In

this case, no compensation, indemnity or reimbursement is due to the Supplier.

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The Dealer also has the right to proceed with the termination with immediate effect for any fraudulent activity

carried out by the Supplier, including without limitation, those indicated below:

a. Violation of the legislation relating to the GAD, including that of a regulatory and concessionary

nature (e.g. concession agreement);

b. violation of money laundering or terrorist financing laws;

c. opening of a gaming account with the Concessionaire by the Supplier and/or subjects related to the

same (including relatives and in-laws and cohabitants);

d. use of means, including IT, contrary to the relevant legislation (by way of example, spam, bots,

multiple registrations on the site of the Concessionaire of the same player, etc.).

In the event that one or more of the causes of termination envisaged occurs, the right of the Concessionaire to request

compensation for any related damage remains unaffected.

10. Final conditions

The Parties establish that, for any dispute relating to the validity, effectiveness, interpretation and execution of the

contract and/or in any case arising from or caused by the same, the court of Ravenna will have exclusive jurisdiction.

The Supplier undertakes to indemnify and hold the Licensee harmless from any liability towards third parties in

relation to the activity covered by this contract, including penalties and/or charges of any kind to be borne by the

Licensee deriving from the violation by the Supplier of the applicable legislation, with the express exemption of the

Concessionaire from any burden of assessment and/or control in this regard.

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ANNEX 1

SUBJECT: Information pursuant to and by effect of articles 13 and 14 of the GDPR 2016/679 and of the

current national legislation relating to the protection of the processing of personal data.

MAC SRL provides the data subject with the information referred to in articles 13 and 14 of the GDPR 2016/679

regarding the processing of personal data concerning him.

Data Controller.

The Data Controller is MAC SRL, with headquarters in Via Martiri Baffè, 2/A - 48020 Sant'Agata Sul Santerno

(RA) - Italy.

Data Protection Officer (DPO or RPD).

The Data Controller has designated a Data Protection Officer (DPO/RPD), who may be contacted by the Data

Subject for all matters relating to the processing of personal data and the exercise of the rights deriving from the

GDPR 2016/679. The contact details of the DPO/RPD are as follows: rpd@legalmail.it.

Purpose and legal basis of the processing.

The collection and processing of personal data are carried out in order to conduct:

1. the fulfillment of all the operations imposed by regulatory obligations, including the possible evaluation of

the supplier (processing necessary to fulfill a legal obligation to which the Data Controller is subject

pursuant to Art. 6 paragraph 1 letter c) of the GDPR 2016 /679);

2. operations strictly connected and instrumental to the initiation of contractual relationships, including the

acquisition of information preliminary to the conclusion of the Contract (processing necessary for the

execution of a contract of which the Data Subject is a party or for the execution of pre-contractual measures

adopted on request of the same pursuant to article 6 paragraph 1 letter b) of the GDPR 2016/679);

3. the management of relations with the Supplier for administration, accounting, orders, shipments, invoicing,

services, management of any out-of-court settlement of disputes where envisaged (processing necessary

for the execution of a contract of which the interested party is a party or at the execution of pre-contractual

measures adopted at the request of the same pursuant to Article 6, paragraph 1, letter b) of the GDPR

2016/679);

4. the management of any judicial dispute (processing attributable to the legitimate interest of the Data

Controller pursuant to Art. 6 paragraph 1 letter f) GDPR 2016/679, strictly limited to the assessment,

exercise and defense of a right in court).

The collection and recording of data will take place in compliance with the principles set forth in Art. 5 GDPR

2016/679, namely: for specific, explicit and legitimate purposes and with methods compatible with these purposes,

in the context of the processing necessary for the functioning of the business activity; exactly and if necessary with

the appropriate updates. So that they are relevant, complete and not excessive with respect to the collection purposes;

so that their conservation is functional to the period of time necessary for the purpose for which they were collected

and subsequently processed according to the GDPR 2016/679 and the national legislation in force.

Personal data may be processed with the aid of both paper and telematic tools, or in any case suitable for recording

and memorizing the data, and in any case in such a way as to guarantee its security and protect the maximum

confidentiality of the interested party. Specific security measures will be observed to prevent data loss, illicit or

incorrect use and unauthorized access in full compliance with art. 32 of the GDPR 2016/679 and of the current

national legislation.

Mandatory or optional nature of the provision of data and consequence of any refusal.

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The provision of personal data necessary for the fulfillment of legal obligations, for the establishment of the

contractual relationship or for its execution is mandatory. Failure to provide data will make it impossible to follow

up on your requests or execute the contract.

Data communication.

Without prejudice to compliance with current regulations and in particular with the principles referred to in Art. 5

GDPR 2016/679, personal data may be communicated, exclusively for the pursuit of the purposes mentioned in this

information, to:

▪ Companies belonging to the same business group;

▪ Subjects to whom it is necessary to communicate the data for the execution of a contract of which the

interested party is a part or for the execution of pre-contractual measures adopted at the request of the same,

as well as, in general, for the pursuit of the purposes mentioned in this information;

▪ Subjects in charge of credit management such as for example, factoring companies, credit institutions, debt

collection companies, credit insurance companies, and commercial information companies;

▪ In particular, subjects who carry out processing on behalf of the Data Controller as Managers pursuant to

art. 28 GDPR 2016/679, such as, by way of example but not limited to: professionals and/or companies

responsible for carrying out activities in the administrative-accounting, legal, commercial, managerial,

technical, technical-IT fields. The complete and updated list of the Managers may be known, to those

entitled, upon mere request at the headquarters of the Data Controller;

▪ Subjects authorized to access the data by current legislation and/or to whom data must be communicated

in the execution of legal obligations.

Personal data may be processed by employees and collaborators assigned to the competent offices of the Data

Controller, explicitly authorized for processing on the basis of Art. 29 of the GDPR 2016/679 and the current

national legislation.

Data transfer abroad.

Personal data may be communicated and/or transmitted abroad only for the pursuit of the purposes referred to in

this information, or for exclusively technical reasons related to the structure of the company Information System

and/or the application of technical and organizational security measures deemed suitable by the Data Controller (art.

32 GDPR 2016/679), and exclusively in compliance with the articles 44 ss of the GDPR 2016/679.

Data retention times.

Without prejudice in any case to compliance with art. 5 GDPR 2016/679 ("conservation limitation principle"), the

data will be stored in our archives according to the following parameters:

▪ Data processed for the fulfillment of the obligations pursuant to art. 2220 of the civil code: 10 years, without

prejudice to any delayed payments of the fees which justify the extension;

▪ Data processed for supplier evaluation purposes: 36 months;

▪ Data processed for purposes other than the previous ones, in the context of the contractual relationship and

referred to in this information notice: until the expiry of the contract and/or of the commercial supply

relationship.

In relation to the specific statute of limitations established by the law, the data necessary for the assessment, exercise

or defense of a right could be subject to longer retention times.

The verification of the obsolescence of the data stored in relation to the purposes for which they were collected is

carried out periodically.

Rights of the interested party.

With regard to personal data, the Data Subject may exercise the rights provided within the limits and under the

conditions set forth in articles 15 to 22 of the GDPR 2016/679 and by the national legislation in force. In particular,

the GDPR attributes to the interested party:

▪ Right of access (art. 15 GDPR 2016/679);

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▪ Right to rectify inaccurate personal data and right to integrate incomplete personal data (art. 16 GDPR

2016/679);

▪ Right to erasure (art. 17 GDPR 2016/679);

▪ Right to restriction processing (art. 18 GDPR 2016/679);

▪ Right to request the recipients to whom any corrections or cancellations or limitations of treatment have

been communicated (art. 19 GDPR 2016/679);

▪ Right to data portability (art. 20 GDPR 2016/679);

▪ Right to opposition (art. 21 GDPR 2016/679);

▪ Right not to be subjected to a decision based solely on automated processing (art. 22 GDPR 2016/679).

In case of signing any form of consent to the processing, it should be noted that the Data Subject may revoke it at

any time, without prejudice to the mandatory obligations established by current legislation at the time of the

revocation request, by contacting the Data Controller at the following e-mail address: info@netwin.it.

Right to lodge a complaint.

The Data Subject who believes that the processing of personal data takes place in violation of the provisions of the

GDPR 2016/679 has the right to lodge a complaint with the supervisory authority of the European Union State

member in which he habitually resides, works, or of the place in which the alleged violation occurred, as provided

for by art. 77 GDPR 2016/679, or to take the appropriate judicial offices.