COOKIE POLICY

CLUB AXO LLC

Version 1.1 | Effective 1 September 2026

This Cookie Policy describes the use by Club AXO LLC (the “Company”, “we”, “us” or “our”) of cookies and similar technologies on the Club AXO website, mobile applications and kiosks (the “Platform”). It is to be read together with the Privacy Policy, which governs the handling of personal information generally.

Capitalised terms used but not defined in this Policy have the meanings given in clause 1 of the Terms and Conditions.

1. SCOPE AND DEFINITIONS

1.1 Cookies. A cookie is a small text file stored on a device by a website, which enables the website to recognise the browser, to retain information between pages and visits, and to analyse use of the website.

1.2 Similar technologies. In this Policy, references to cookies include local storage in a browser, software development kits within mobile applications, pixels and tags within emails and pages, and device fingerprinting used for fraud prevention and geolocation.

2. CATEGORIES OF COOKIE

2.1 Strictly necessary. These cookies are required for the operation of the Platform and cannot be disabled. They maintain your session, retain items within a purchase flow, distribute traffic across servers, protect against fraud and automated attack, enforce geographic eligibility, and record your cookie preferences. Disabling these cookies at browser level will prevent parts of the Platform from functioning.

2.2 Functional. These cookies retain elections you have made, including language, display preferences, dismissal of a notice, and responsible-gaming display settings.

2.3 Analytics and performance. These cookies record use of the Platform in aggregate, including pages visited, games launched, errors encountered and page load times. The Company uses this information to correct defects and to improve the Platform. Analytics data is not used to make determinations concerning an individual Account.

2.4 Advertising and targeting. These cookies may be set by the Company or by advertising partners in order to measure the performance of the Company’s advertising and, where permitted, to display the Company’s advertising on other websites. Where the use of such cookies constitutes a “sale” or “share” of personal information under State law, you may opt out in accordance with clause 5.

2.5 Security, fraud prevention and geolocation. These technologies support the identity, device and location checks described at clauses 5 and 6 of the Terms and Conditions, including device fingerprinting used by the Company’s verification provider to confirm location and to detect duplicate Accounts and fraud. These are treated as strictly necessary, the Company being unable to operate a lawful sweepstakes without them.

3. THIRD-PARTY COOKIES

3.1 Categories of setter. Certain cookies are set by service providers of the Company, being: its identity-verification and geolocation provider; its payment processor; its game content providers; its hosting and content-delivery providers; its analytics provider; and its email and messaging providers.

3.2 Governing policies. The handling of information collected through such cookies is governed by the privacy policies of those providers.

3.3 Restriction on use. The Company does not permit its service providers to use information collected through cookies on the Platform for their own unrelated purposes.

4. DURATION

4.1 Session cookies. Session cookies are deleted on closure of the browser.

4.2 Persistent cookies. Persistent cookies remain on a device for a defined period, ordinarily not exceeding 12 months for functional and analytics cookies and a shorter period for most advertising cookies, or until deleted.

4.3 Security identifiers. Security and fraud-prevention identifiers are retained in accordance with clause 8 of the Privacy Policy.

5. YOUR CHOICES

5.1 Cookie preferences tool. Non-essential cookies may be accepted or declined, and that election varied at any time, through the cookie preferences tool in the Platform footer. Cookies within clauses 2.1 and 2.5 cannot be disabled by that tool, the Platform being unable to operate without them.

5.2 Global Privacy Control. The Company honours the Global Privacy Control signal as a request to opt out of the sale or sharing of personal information and of targeted advertising, in every State in which that signal is required to be honoured. Where your browser or extension transmits that signal, no further action is required.

5.3 Do Not Track. The Company does not respond to Do Not Track signals, no common industry standard existing in respect of them.

5.4 Do Not Sell or Share. The “Do Not Sell or Share My Personal Information” link in the Platform footer records an opt-out from the sale or sharing of personal information and from targeted advertising. An opt-out may also be requested by email to marketing@clubaxo.com.

5.5 Browser and device controls. Cookies may be blocked or deleted through browser settings, and advertising identifiers may be reset or limited through mobile operating-system settings. Blocking all cookies will prevent sign-in and will render the Platform inoperable.

5.6 Industry opt-outs. Interest-based advertising from participating companies may be declined through the Digital Advertising Alliance at optout.aboutads.info and the Network Advertising Initiative at optout.networkadvertising.org. Those are third-party facilities which the Company does not control.

6. KIOSKS

6.1 A Company kiosk is a shared device in a public place.

6.2 Cookies and local storage on a kiosk are used only for the purposes of the session then in progress and are cleared on the termination of that session.

6.3 Credentials must not be saved on a kiosk, and users must sign out on completion.

6.4 Kiosks are hosted by independent businesses. Clause 24 of the Terms and Conditions applies.

7. AMENDMENTS

7.1 The Company may amend this Policy to reflect changes in the technologies it uses or in applicable law.

7.2 An amended version takes effect on publication on the Platform, with a revised effective date.

8. CONTACT INFORMATION

Club AXO LLC 1309 Coffeen Avenue, Suite 1200, Sheridan, WY 82801