Privacy Policy

Inting Technologies Inc., a corporation incorporated under the Canada Business Corporations Act, R.S.C. 1985, c. C-44, operating under the trade name DuelSkill ("DuelSkill," "Organization," "we," "our," or "us"), has developed and maintains this Privacy Policy in accordance with the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 ("PIPEDA"), together with any substantially similar provincial legislation and applicable international data protection frameworks. This document governs the manner in which personal information is collected, processed, safeguarded, retained, and disclosed in connection with your relationship with DuelSkill and your use of duelskill.com (the "Platform").

The obligations and disclosures contained herein apply to personal information obtained through any of the following channels: promotional content, applications, or integrations bearing DuelSkill branding that appear on third-party websites or digital services and that expressly reference this Privacy Policy; native desktop applications distributed through the Platform that operate independently of a web browser environment; electronic correspondence exchanged between you and DuelSkill, whether by email, in-platform messaging, or other digital communication medium; and direct interaction with the Platform itself.

For the avoidance of doubt, this Privacy Policy does not govern information collected through offline means nor through any website, application, or service operated by DuelSkill or any third party—including affiliates and subsidiaries—other than the Platform, even where such properties maintain hyperlinks to or from the Platform. Similarly, personal information collected independently by third parties, including through advertising or content that may appear on or link to the Platform, falls outside the scope of this document and is subject to the privacy policies of those respective parties.

By accessing, browsing, or otherwise making use of the Platform, any associated desktop software, or any electronic communication channel maintained by DuelSkill, you signify your informed and voluntary consent to the collection, use, disclosure, and retention practices set forth in this Privacy Policy. If you do not accept these practices in their entirety, you must discontinue all use of the Platform and related services immediately. This Privacy Policy is a living document subject to periodic revision (see Section 22: Policy Amendments); your continued engagement with the Platform following any such revision shall constitute acceptance of the amended terms, and you are accordingly encouraged to consult this document at regular intervals.

The Platform is not intended for, and may not be used by, any individual under the age of eighteen (18). No parental or guardian consent, authorization, or verification shall permit or authorize any individual under the age of eighteen to access, register for, or use the Platform or any of its features. In keeping with PIPEDA's requirements concerning meaningful consent, DuelSkill maintains a strict obligation to promptly expunge any personal information determined to have been furnished by an individual under eighteen (18) years of age, regardless of whether parental or guardian authorization was purportedly obtained. Should you have reason to believe that such information has been collected from a person under the age of eighteen, you are urged to notify DuelSkill immediately using the contact details provided at the conclusion of this Privacy Policy.

The Platform is designed exclusively for use by persons aged eighteen (18) and older. No individual below this age is permitted to create an account, execute any transaction, engage with interactive or community features, furnish personal identifiers such as names, telephone numbers, email addresses, physical addresses, or screen names, or otherwise interact with the Platform in any capacity. DuelSkill neither designs its services to attract individuals under the age of eighteen nor directs any data collection efforts toward such persons.

When you voluntarily interact with the Platform—or when DuelSkill receives data from affiliated business partners and service providers—the following categories of personally identifiable information ("PII") may be collected: financial account or payment instrument details; profile imagery and photographic recordings; telephone numbers and electronic mail addresses; taxpayer identification numbers; legal names and physical addresses; government-issued identification documents (such as passports, driver's licences, and national identity cards) together with supporting verification materials submitted in connection with identity or withdrawal verification, including utility invoices, bank statements, or other institutional correspondence; gaming platform identifiers, in-game usernames, and linked third-party account credentials; and any additional designation or credential by which direct or indirect communication with you may be established, whether through digital or physical channels.

Beyond PII, DuelSkill may collect or receive the following through direct submission:

• Referral source indicators, click and share events, error logs, and navigational path data with associated timestamps;
• Financial particulars and fulfillment records arising from transactions executed through the Platform, where provision of payment information may be a prerequisite to order processing;
• Search terms entered within Platform interfaces;
• Match participation records, outcome determinations, voting submissions, skill ratings, rankings, and competitive performance metrics;
• In-platform communications, including chat messages exchanged with other users, dispute-related correspondence, and support requests;
• Copies and records of correspondence directed to DuelSkill, including the associated electronic mail addresses;
• Responses furnished to voluntary research surveys or questionnaires; and
• Data submitted via Platform forms in connection with account creation, service subscriptions, content publication, issue reporting, or participation in DuelSkill-sponsored contests and promotions.

Independent of the information you provide directly, DuelSkill deploys cookies, tracking pixels, and comparable technologies to gather data as you navigate the Platform. This information may include—or may subsequently be linked to—PII obtained through other means or received from third parties.

6.1 Data Gathered Automatically

Automated systems may record:

• Records of additional accounts observed accessing the Platform from a shared network address;
• Hardware and software attributes of the accessing device, including browser type, operating system version, and network address; and
• Session-level activity data comprising traffic volume, geographic locality signals, server logs, resource access sequences, and communication metadata.

These same technologies may track your activity across other digital properties and over extended time periods (cross-site behavioral analytics). Non-identifying technical identifiers—such as gaming platform handles, account usernames, device or advertising identifiers, analytical markers, and browser fingerprints—may also be captured and do not, in isolation, constitute PII, though they may be correlated with PII held by DuelSkill.

6.2 Purposes of Automated Collection

Data collected through automated means serves to improve the Platform and deliver a more individualized experience, including by enabling DuelSkill to:

• Recognize returning visitors and restore their prior session context;
• Accelerate the responsiveness of in-Platform search functions;
• Retain user-specified preferences to tailor the Platform's presentation; and
• Evaluate aggregate audience composition and usage trends.

6.3 Cookies

A cookie is a small-format data file written to the storage of your device. The Platform will issue cookies automatically unless your browser has been configured to reject them. You may adjust your browser settings to decline cookies at any time; however, doing so may render certain Platform features inaccessible or cause them to function in a degraded manner.

6.4 Tracking Pixels

Certain Platform pages and electronic messages sent by DuelSkill embed tracking pixels—also known as pixel tags, clear GIFs, or single-pixel images—which enable the measurement of page visits, email open rates, content popularity, and server integrity, among other website-related statistics.

DuelSkill collects information pertaining to the internet connection through which you access the Platform, the hardware and software configuration of your device, and granular usage metrics that describe the manner and frequency of your interactions with Platform resources.

The DuelSkill desktop application, once installed and active, automatically captures the following categories of data during gameplay sessions and at such other times as the application determines necessary for match verification, fraud prevention, and platform integrity:

• Continuous screen recordings and periodic screenshots of your display output;
• Keyboard input events and mouse input events, including timestamps and positional data; and
• System-level information including operating system version, hardware configuration, installed drivers, running processes, and network connectivity attributes.

8.1 Scope and User Responsibility

Screen capture operates indiscriminately on the entirety of your visible display. DuelSkill assumes no responsibility for the incidental recording of personal information, confidential communications, financial data, or any other sensitive material that may be visible on screen at the time of capture. You bear sole responsibility for ensuring that no information you wish to keep private is displayed during any active recording session.

8.2 Licence and Retention

By using the desktop application, you grant DuelSkill an irrevocable, perpetual, worldwide, royalty-free licence to capture, record, process, store, analyze, and create derivative works from all data collected through the application. This licence extends to the use of recordings and derived data for match verification, dispute resolution, fraud and cheat detection, training and improvement of artificial intelligence and machine learning models, automated verification system development, statistical analysis, platform optimization, and any other purpose reasonably related to the operation or improvement of the Services. Recordings and input data submitted or captured through the application cannot be deleted, withdrawn, or revoked once received by DuelSkill and may be retained indefinitely (see Section 17: Privacy Rights, Data Retention).

Certain information that you elect to publish within public areas of the Platform or to transmit to other users or external parties constitutes "User Contributions." Because DuelSkill has no ability to govern what recipients or other Platform users do with material you have chosen to share, the confidentiality of User Contributions cannot be assured, and any such disclosure is undertaken entirely at your own risk.

In addition to data collected directly and through automated means, DuelSkill may receive personal information from external sources, including business partners, affiliated service providers, and advertising networks. Such information may be combined with data already held by DuelSkill and is subject to the terms of this Privacy Policy upon receipt.

DuelSkill bears no governance authority over the data collection regimes maintained by third parties whose content, applications, or promotional materials appear on the Platform. These entities—which may include advertising intermediaries, content distribution networks, and application vendors—set their own technical and privacy standards independently of DuelSkill. Should you wish to understand the data practices behind a particular advertisement or piece of targeted content, any inquiry must be directed to the third party responsible for that material. Mechanisms for declining targeted advertising from participating providers are described in Section 15: User Rights and Choices.

The third-party services integrated into the Platform maintain autonomous instrumentation—including but not limited to browser storage objects (cookies), embedded image elements (pixel tags), and comparable tracking mechanisms—capable of recording your activity both within and beyond the Platform, potentially across multiple digital properties and over indefinite time horizons. The resulting datasets may contain personally identifiable elements or may be merged with personal information these parties have obtained through other channels, and are commonly leveraged to deliver advertisements and content calibrated to inferred user preferences and observed browsing patterns.

DuelSkill employs artificial intelligence algorithms, machine learning models, optical character recognition, computer vision systems, and other automated processing technologies in connection with the operation of the Platform. These systems are applied to, among other things:

• Verification of match outcomes based on submitted recordings, screenshots, and input data;
• Detection of cheating, fraud, collusion, match manipulation, and other prohibited conduct;
• Analysis and classification of evidence submitted in connection with disputes; and
• Rendering of match result determinations and enforcement actions, including account restrictions, fund forfeitures, and permanent bans.

12.1 Training Data

Recordings, screenshots, input logs, match metadata, and other data collected through the Platform and the desktop application may be used as training data for the development and refinement of DuelSkill's AI and machine learning models. This use is covered by the licence grant described in Section 8.2 and the Terms of Service.

12.2 Automated Determinations

Determinations produced by automated systems—including match outcome verification, cheating detection, and enforcement actions—may be rendered without human intervention and are final and binding unless subsequently reviewed and reversed by a human moderator at DuelSkill's sole discretion. DuelSkill makes no warranty or representation regarding the accuracy, completeness, or reliability of any output produced by its automated systems. For information regarding your rights in connection with automated decision-making, including the right to request human review where applicable, refer to Section 17: Privacy Rights.

In accordance with PIPEDA's requirement that personal information be collected, used, and disclosed only for purposes that a reasonable person would consider appropriate in the circumstances (Principle 4.3), DuelSkill processes collected information, including PII, for the purposes set forth below.

13.1 Service Delivery and Contractual Fulfilment

• Provision of information, products, features, or services that you have requested or that are necessary for the performance of any agreement between you and DuelSkill, including billing, invoicing, and collection activities;
• Fulfilment of the specific purpose for which information was originally submitted;
• Facilitation of participation in interactive, competitive, or community features available on the Platform; and
• Account administration, including subscription lifecycle notifications such as renewal and expiration alerts.

13.2 Platform Operations, Improvement, and Development

• Presentation of Platform content in a manner optimized for your device and preferences;
• Protection of Platform integrity, including fraud detection, abuse prevention, and infrastructure monitoring;
• Analysis of usage patterns to inform the design and development of new services, features, and offerings; and
• Notification of material changes to Platform functionality, available services, or applicable policies.

13.3 Communication and User Support

• Response to inquiries, investigation of reported concerns, and provision of technical or account-related assistance, including quality assurance review of support interactions; and
• Distribution of periodic informational communications, including newsletters and Platform updates.

13.4 Compliance and Enforcement

• Verification of adherence to the Terms of Service and other applicable Platform policies; and
• Exercise and enforcement of legal rights arising from your relationship with DuelSkill.

13.5 Financial Regulation and Tax Reporting

• Compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, S.C. 2000, c. 17 ("PCMLTFA"), including the filing of reports with the Financial Transactions and Reports Analysis Centre of Canada ("FINTRAC") as required;
• Preparation and issuance of tax information returns (T4A, T5, or other slips) to the Canada Revenue Agency and to users whose winnings or prizes exceed applicable reporting thresholds, and the corresponding issuance of IRS Forms 1099-MISC, 1099-K, or W-2G for users subject to United States tax jurisdiction; and
• Withholding of amounts required under the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.), including non-resident withholding under Part XIII, and under applicable United States backup withholding provisions.

13.6 Automated Processing and Platform Integrity

• Operation, training, and improvement of artificial intelligence and machine learning models used for match verification, fraud detection, and enforcement (see Section 12); and
• Escrow management, prize calculation, fund distribution, and the investigation and resolution of chargebacks, payment disputes, and suspected fraudulent transactions.

13.7 Consent-Based and Separately Disclosed Purposes

• Processing for any additional purpose specifically described to you at the time of information collection; and
• Processing for any other purpose for which you have provided express, informed consent, which consent may be withdrawn at any time in accordance with PIPEDA Principle 4.3.8.

DuelSkill may also process your contact information to communicate regarding its own offerings and those of selected third parties that may be relevant to your interests. You may object to this use at any time by submitting a written request to the contact address specified in Section 23. Additional information regarding your choices is set forth in Section 15: User Rights and Choices.

DuelSkill discloses personal information only where a reasonable person would consider the disclosure appropriate in the circumstances, consistent with PIPEDA Principle 4.5. Statistical, de-identified, or aggregated data that cannot reasonably be used to identify any natural person may be shared without limitation.

PII may be disclosed in the following categories of circumstances:

14.1 Consent and Purpose-Driven Disclosures

• Where you have granted express, informed consent to the disclosure;
• To accomplish the specific objective for which the information was originally furnished; and
• For any supplementary purpose communicated to you at the point of collection.

14.2 Operational and Service-Related Disclosures

• To corporate subsidiaries and affiliated entities within the DuelSkill corporate group;
• To vendors, consultants, and other agents retained by DuelSkill to perform functions on its behalf, who are bound by written agreements requiring them to handle such information consistently with this Privacy Policy and to implement appropriate technical and organizational safeguards in accordance with PIPEDA Principle 4.7.

14.3 Corporate Transaction Disclosures

• To a purchaser, assignee, or successor entity in connection with any merger, acquisition, divestiture, corporate reorganization, dissolution, or transfer of all or a portion of DuelSkill's assets—including proceedings under the Bankruptcy and Insolvency Act, R.S.C. 1985, c. B-3—where personal information forms part of the transferred assets.

14.4 Legal Obligations and Protective Measures

• In response to a subpoena, court order, regulatory demand, or other compulsory legal process issued by a court of competent jurisdiction or governmental authority; and
• Where DuelSkill determines, acting reasonably, that disclosure is necessary to safeguard its rights, property, or commercial interests, or to protect the safety of its users or the public, including the sharing of information with other organizations for the purposes of detecting fraud and mitigating credit exposure.

14.5 Regulatory, Law Enforcement, and Financial Disclosures

• To FINTRAC or any other financial intelligence unit as required under the PCMLTFA or comparable foreign legislation;
• To law enforcement agencies and fraud prevention databases where DuelSkill has reasonable grounds to suspect that an offence has been committed or that the information is relevant to an ongoing investigation; and
• To payment processors, card networks, and financial institutions in connection with chargeback representment, fraud reporting, or the recovery of funds, which may include disclosure of transaction records, account activity logs, IP addresses, device identifiers, and match data.

PIPEDA affords individuals meaningful control over how their personal information is collected, used, and disclosed. DuelSkill is committed to honouring these rights and has established the mechanisms described below to facilitate their exercise.

15.1 Rights Under PIPEDA

In addition to any rights set forth elsewhere in this Privacy Policy, you are entitled to:

• Request access to the personal information DuelSkill holds about you and receive an account of how it has been used and to whom it has been disclosed (Principle 4.9);
• Challenge the accuracy or completeness of your personal information and have it amended where warranted (Principle 4.9.5); and
• Withdraw your consent to the continued collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions and upon reasonable notice (Principle 4.3.8). DuelSkill will inform you of the consequences of withdrawal upon receipt of your request.

15.2 Opting Out of Communications and Data Sharing

All opt-out requests—whether relating to promotional communications sent by DuelSkill, the sharing of your PII with unaffiliated organizations for their own marketing purposes, or the use of your information for advertisement targeting—may be submitted by written correspondence to the contact address specified in Section 23. DuelSkill will act on valid requests within thirty (30) days of receipt, or such shorter period as applicable law may require.

15.3 Browser and Device-Level Controls

Most web browsers allow you to manage or disable cookies through their settings interface. Restricting cookies may impair the functionality of certain Platform features. DuelSkill does not currently alter its data collection or use practices in response to "Do Not Track" signals transmitted by web browsers; however, the opt-out and self-regulatory mechanisms described in Section 15.4 remain available to you regardless of your browser's signal configuration.

15.4 Third-Party Advertising Opt-Out Programmes

The behavioural advertising practices of third parties operating on or through the Platform fall outside DuelSkill's technical purview. However, several industry self-regulatory bodies maintain centralized opt-out registries through which you may decline targeted advertising from participating networks:

• Network Advertising Initiative: http://optout.networkadvertising.org/
• Digital Advertising Alliance: http://optout.aboutads.info/

Users of mobile devices or alternative platforms should consult the privacy documentation provided by the manufacturer or operating system vendor for device-specific advertising controls.

You should be aware that User Contributions published through public-facing areas of the Platform may propagate beyond DuelSkill's direct control. Even after you remove such content, residual copies may persist in search-engine indices, web archive services, content delivery network caches, or the personal records of other users who accessed the material while it was publicly available. Your posting of User Contributions and any subsequent access to or re-use of that material by third parties remains subject to the Terms of Service.

You may submit a written request to the contact address specified in Section 23 to obtain access to, rectify, or erase PII that DuelSkill holds about you. DuelSkill reserves the right to refuse a rectification request where granting it would introduce factual inaccuracies into the record or would contravene an obligation imposed by applicable law. Because PII is integral to the maintenance of your account, a request for comprehensive erasure of PII can only be fulfilled through permanent closure and deletion of the associated user account.

17.1 Canadian Privacy Rights (PIPEDA)

As a federally incorporated Canadian entity, DuelSkill is subject to the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 ("PIPEDA") and applicable provincial privacy legislation. Under PIPEDA, individuals possess the following rights with respect to their personal information:

• The right to access personal information held by the Organization and to be informed of its use and disclosure;
• The right to challenge the accuracy and completeness of personal information and have it amended as appropriate;
• The right to withdraw consent to the collection, use, or disclosure of personal information, subject to legal or contractual restrictions and upon reasonable notice;
• The right to file a complaint with the Office of the Privacy Commissioner of Canada concerning the Organization's information handling practices.

DuelSkill adheres to the ten fair information principles set forth in Schedule 1 of PIPEDA, including accountability, identifying purposes, consent, limiting collection, limiting use, disclosure and retention, accuracy, safeguards, openness, and individual access.

17.2 United States State Privacy Rights

Several U.S. states have enacted comprehensive consumer privacy legislation that may afford their residents supplementary rights with respect to PII processed by DuelSkill. The following summary is organized by category of right; the specific states in which each right is currently operative are noted parenthetically. This summary is not exhaustive, and additional state-level privacy obligations may apply as new legislation takes effect.

• Right to know and confirm — You may request confirmation as to whether DuelSkill processes your PII and, if so, obtain a description of the categories and specific elements of data held (Colorado, Connecticut, Utah, Virginia).
• Right to deletion — You may request erasure of PII that DuelSkill has collected from or about you, subject to statutory exceptions (Colorado, Connecticut, Utah, Virginia).
• Right to portability — You may obtain a copy of your PII in a readily usable, machine-readable format suitable for transmission to another controller (Colorado, Connecticut, Utah, Virginia).
• Right to rectification — You may direct DuelSkill to correct inaccurate PII, having regard to the nature of the data and the objectives of its processing (Colorado, Connecticut, Virginia).
• Right to opt out of targeted advertising and data sales — You may direct DuelSkill to cease processing your PII for the purpose of delivering targeted advertisements or for transactions that qualify as a "sale" under the applicable statute (Colorado, Connecticut, Utah, Virginia).
• Right to opt out of automated profiling — You may object to profiling activities that produce decisions with legal consequences or comparably significant effects on your person (Colorado, Connecticut, Virginia).
• Nevada opt-out right — Nevada residents may submit a verified request directing DuelSkill not to sell certain categories of PII, as defined under Nevada Revised Statutes Chapter 603A.

17.3 European Economic Area Privacy Rights (GDPR)

To the extent that DuelSkill processes personal data of individuals located within the European Economic Area ("EEA"), such processing is subject to Regulation (EU) 2016/679 (the "General Data Protection Regulation" or "GDPR") and applicable national implementing legislation. For the purposes of the GDPR, Inting Technologies Inc. acts as the data controller with respect to the personal data of such individuals.

Legal Bases for Processing

DuelSkill processes personal data on the following legal bases as applicable:

• Contractual necessity (Article 6(1)(b) GDPR): Processing necessary for the performance of the Agreement between you and DuelSkill, including account registration, match facilitation, escrow management, prize distribution, and withdrawal processing;
• Legitimate interests (Article 6(1)(f) GDPR): Processing necessary for the purposes of DuelSkill's legitimate interests, including fraud detection and prevention, platform security, anti-cheat enforcement, automated verification system operation and improvement, dispute resolution, and analytics for platform optimization, except where such interests are overridden by your fundamental rights and freedoms;
• Legal obligation (Article 6(1)(c) GDPR): Processing necessary for compliance with applicable legal obligations, including tax reporting, anti-money laundering requirements, regulatory requests, and law enforcement cooperation;
• Consent (Article 6(1)(a) GDPR): Where processing is based on your freely given, specific, informed, and unambiguous consent, including for promotional communications and optional data collection. Consent may be withdrawn at any time without affecting the lawfulness of processing performed prior to withdrawal.

Rights of EEA Data Subjects

In addition to the rights described elsewhere in this Privacy Policy, individuals located within the EEA possess the following rights under the GDPR:

• Right of access (Article 15): The right to obtain confirmation of whether personal data is being processed and, if so, to access such data together with information regarding the purposes of processing, categories of data, recipients, and retention periods;
• Right to rectification (Article 16): The right to obtain correction of inaccurate personal data and completion of incomplete personal data;
• Right to erasure (Article 17): The right to obtain deletion of personal data where the data is no longer necessary for its original purpose, where consent has been withdrawn, where processing is unlawful, or where erasure is required by law, subject to applicable exceptions including data required for legal compliance, dispute resolution, or the establishment, exercise, or defence of legal claims;
• Right to restriction of processing (Article 18): The right to obtain restriction of processing where the accuracy of data is contested, where processing is unlawful but erasure is not desired, where data is no longer needed but required for legal claims, or pending verification of legitimate interests;
• Right to data portability (Article 20): The right to receive personal data provided to DuelSkill in a structured, commonly used, and machine-readable format, and to transmit such data to another controller, where processing is based on consent or contractual necessity and carried out by automated means;
• Right to object (Article 21): The right to object to processing based on legitimate interests, including profiling. DuelSkill shall cease processing unless it demonstrates compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defence of legal claims;
• Rights related to automated decision-making (Article 22): The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you. Where automated match verification systems produce determinations affecting prize distribution or account standing, you may request human review of any such determination by contacting the address specified herein.

International Data Transfers

Personal data of EEA-based individuals is transferred to and processed in Canada, where DuelSkill is headquartered. The European Commission has recognized Canada as providing an adequate level of data protection for commercial organizations subject to PIPEDA pursuant to Commission Decision 2002/2/EC. Accordingly, transfers of personal data from the EEA to DuelSkill in Canada are made on the basis of this adequacy decision and do not require additional transfer mechanisms. Where personal data is further transferred to service providers or sub-processors located in jurisdictions that have not received an adequacy determination, DuelSkill shall ensure that appropriate safeguards are in place, including Standard Contractual Clauses adopted by the European Commission or other mechanisms approved under the GDPR.

Data Retention

DuelSkill retains personal data for so long as is necessary to fulfill the purposes for which it was collected, to comply with legal and regulatory obligations, to resolve disputes, and to enforce the Agreement. Account information is retained for the duration of the account relationship and for a period of up to five (5) years following account termination or closure, or longer where required by applicable law. Transaction records, match results, and financial data may be retained for a minimum of seven (7) years in accordance with tax reporting and anti-money laundering obligations. Recordings submitted for match verification may be retained indefinitely for fraud prevention, platform integrity, and system improvement purposes, subject to the licence grant set forth in Section 8.2 and the Terms of Service.

Right to Lodge a Complaint

Individuals located within the EEA have the right to lodge a complaint with a supervisory authority in the Member State of their habitual residence, place of work, or place of the alleged infringement if they consider that the processing of their personal data infringes the GDPR.

To exercise any of the foregoing rights, or to appeal a consumer rights request determination, submit correspondence to the contact address specified herein.

18.1 Organizational Safeguards

Pursuant to PIPEDA Principle 4.7, DuelSkill has adopted physical, administrative, and technical safeguards proportionate to the sensitivity of the personal information under its custody. These measures are designed to guard against unauthorized collection, access, use, alteration, reproduction, disclosure, and destruction of PII, and are subject to periodic review and enhancement as threats evolve and as the Organization's operational environment changes.

18.2 Your Role in Protecting Your Information

Effective data protection requires your active participation. You are responsible for preserving the secrecy of any credentials—including passwords and authentication tokens—associated with your account, and for ensuring that such credentials are not disclosed to or shared with any third party. You should also exercise discretion when contributing information to publicly accessible areas of the Platform (for example, forums or community boards), as any content posted in those spaces may be viewed, copied, or redistributed by other users.

18.3 Inherent Limitations

No method of electronic transmission or digital storage is entirely immune to interception, compromise, or failure. Although DuelSkill employs commercially reasonable protections, it cannot warrant that PII transmitted to or from the Platform will remain inviolate in transit or at rest. You acknowledge that any data you transmit over the internet is conveyed at your own risk, and that DuelSkill shall not be liable for any breach of security attributable to the circumvention or defeat of the Platform's protective measures by unauthorized third parties.

In the event of a breach of security safeguards involving personal information under DuelSkill's control, and where the breach creates a real risk of significant harm to affected individuals, DuelSkill will:

• Report the breach to the Office of the Privacy Commissioner of Canada as required by PIPEDA section 10.1 and the Breach of Security Safeguards Regulations, SOR/2018-64;
• Notify affected individuals as soon as feasible, providing a description of the breach, the categories of personal information involved, and the steps DuelSkill has taken or intends to take to mitigate the risk of harm;
• Where required by Regulation (EU) 2016/679, notify the competent supervisory authority within seventy-two (72) hours of becoming aware of the breach and notify affected data subjects without undue delay where the breach is likely to result in a high risk to their rights and freedoms; and
• Comply with any applicable U.S. state breach notification statutes, including notification to state attorneys general and affected individuals within the timeframes prescribed by the relevant state law.

DuelSkill maintains a record of all breaches of security safeguards, regardless of whether reporting thresholds are met, in accordance with PIPEDA section 10.3.

Upon voluntary closure or involuntary termination of your account—whether initiated by you or by DuelSkill pursuant to the Terms of Service—the following data practices apply:

• Account information, transaction records, match history, and associated financial data will be retained for the periods specified in the Data Retention provisions of Section 17, or longer where required by law;
• Recordings, screenshots, and input data previously submitted or captured remain subject to the irrevocable licence described in Section 8.2 and will not be deleted upon account closure;
• Where an account is terminated for violation of the Terms of Service, DuelSkill may retain all associated personal information indefinitely for the purposes of enforcing permanent bans, preventing the creation of new accounts, supporting ongoing or anticipated investigations, and cooperating with law enforcement or regulatory authorities; and
• Personal information may be disclosed to fraud prevention databases and industry-shared registries to the extent necessary to protect the integrity of the Platform and the broader competitive gaming ecosystem.

Any funds remaining in a terminated account are subject to the forfeiture and disbursement provisions set forth in the Terms of Service. DuelSkill bears no obligation to return, refund, or release escrowed funds following account termination for cause.

Inting Technologies Inc. is a federally incorporated Canadian entity headquartered in the Province of Ontario, Canada. The Platform is principally intended for access by individuals located within Canada, the United States, and the European Economic Area ("EEA"). Within the United States, the Services are expressly unavailable to residents domiciled in, or persons accessing the Platform from: Arizona, Hawaii, Iowa, Mississippi, Montana, Nevada, and South Dakota. Within the EEA, the availability of the Services may vary by Member State depending on applicable laws governing skill-based competitions, online gaming, and related activities; users are solely responsible for determining the legality of their participation under the laws of their Member State of residence. The Company makes no representations regarding Platform accessibility, legality, or appropriateness in jurisdictions outside of Canada, the United States, and the EEA. Access from any jurisdiction in which the Services may be prohibited, restricted, or otherwise regulated is undertaken at the user's sole initiative, risk, and responsibility for compliance with all applicable local, national, and supranational laws.

You are encouraged to consult this Privacy Policy at regular intervals, as the "Last Modified" date displayed at the head of this document will reflect the most recent revision. DuelSkill reserves the right to amend any provision of this Privacy Policy at its discretion. Where a revision materially alters the manner in which PII is collected, used, or disclosed, DuelSkill will endeavour to provide advance notice through a combination of a prominent announcement within the Platform interface and direct electronic communication to the email address associated with your account. Amendments become effective upon publication to this page unless a later effective date is expressly specified. It is your responsibility to ensure that DuelSkill holds a current, deliverable email address for your account so that such notices reach you in a timely fashion.

Inquiries or comments regarding this Privacy Policy and DuelSkill data practices should be directed to:

Electronic Mail: support@duelskill.com