PRIVACY POLICY

Versyv, Inc. (“Versyv”) and its online and mobile platform entitled “RiddleVerse” ("we," "our" or "us") believe that your privacy is very important. This Policy outlines the types of personally identifiable information and other data that we will collect from you through your use of our website and mobile application (the "Platform"), and how we will use and when we might disclose such information and data to third parties. Your installation and/or use of the Platform and/or submission of information to us constitute your consent to this Privacy Policy. This Privacy Policy is effective as of September 27th 2016 and has not been modified since that date.

There are two types of information we may collect through your use of the Platform:

1.Personal Information,” which is the type of information that specifically identifies you personally and/or can be used alone to contact you online or offline, such as your full name, physical address, email address, telephone number, photograph, precise geolocation information, credit card information and, in some cases, user names; and

2.Non-Personal Information,” which is information that does not identify you and cannot be used to contact you personally, including information about you such as your date of birth, ZIP code, non-precise geolocation information (e.g., your city), and gender, as well as information about your computer and mobile device, such as your unique device ID, Internet Protocol (IP) address, or other persistent identifiers, and their hardware/software/firmware. Non-Personal Information also includes “Usage Data,” which is anonymous data relating to usage of your computer and/or device, such as the actions you take within and outside of the Platform, the browser and/or device you use, the date and time of your use of the Platform, particular preferences you have chosen, and the URLs you visited and/or apps you used before and after using our Platform. Together, Personal Information and Non-Personal Information may collectively be referred to as “Information.”

Personal Information, Non-Personal Information and Other Information That We Collect and How We Collect It

If you choose to open an account with us, participate in our riddle-solving contests, request support, sign up to receive notifications, or in any other way take steps that require the submission of Information, we will collect all information you submit, which may include Personal Information such as your name, email address, and phone number, and Non-Personal Information such as your date of birth, zip code and/or gender.

If you choose to connect to our Platform through a third-party social network such as Facebook, we may collect Information from your profile on such third-party social networks, such as your name, username, e-mail address, photograph, gender and date of birth.

If you make any purchases through the Platform, in addition to the Personal Information collected as part of the billing process, we, or our third party payment processor, will collect payment information which may include credit card information or information related to third party payment options such as Apple Pay, Pay Pal or Google Wallet.

90111-00002/2550656.1

If you choose to submit your Information to us for any other reason in any other form (e.g., customer service requests, inquiry submissions, etc.), we will collect such Information and use it for the purposes for which you submitted it.

We will only collect Personal Information if you choose to submit it to us. However, we, or third party analytics services on our behalf, may collect Non-Personal Information such as device IDs, IP addresses and other persistent identifiers, as well as Usage Data, whenever you use our Platform. Such Non-Personal Information is not combined with Personal Information unless you choose to submit Personal Information to us.

A special note about cookies: When you use the Platform, we may also use “cookies,” “web beacons” or similar tracking technologies, which are tiny files that identify your computer or mobile device that collect and store Usage Data relating to such computer or mobile device. Should you choose to submit Personal Information to us, we may link that Usage Data to your Personal Information. You may be able to disable cookies and other tracking technology; however, some of our Platform will not function properly if you do so and you may lose access to the Platform you wish to use.

Use of the Personal Information That We Collect

We will use your Personal Information to:

Provide you with the services or functionality you have requested, including registering you for contests, effectuating purchases, and processing any prizes you’ve won;

Respond to any inquiries you have made through our customer service features;

We may also contact you to generally promote our Platform or alert you to special offers or features. We will provide you with the opportunity to opt out of receiving such communications in the future. You may also opt out of receiving such communications at any time in accordance with the instructions provided in this Privacy Policy.

Use of the Non-Personal Information That We Collect

Non-Personal Information may be used by us for administrative, analytical, research, optimization, security and other purposes. Specifically, we may use your Non-Personal Information (including Usage Data collected through tracking technologies) to:

Track your use of our Platform to help us learn more about your preferences and tendencies so that we can personalize your experience, provide you with notifications that are tailored to you, and otherwise enhance your experience;

Determine which features, hubs, products and services users enjoy the most so we can enhance and improve our Platform;

Evaluate the success of certain features;

Protect against crime or fraud, or to address other security concerns.

Disclosure of the Information That We Collect

We will not sell, rent or transfer your Personal Information to third parties for marketing purposes without your prior consent. Specifically, we will not disclose your Personal

90111-00002/2550656.1

Information to third parties for their direct marketing purposes unless you first “opt in” or affirmatively agree to the disclosure.

In order to provide certain aspects of our Platform, such as payment processing and prize fulfillment, we may be required to share your Information, including Personal Information, with third parties with whom we have contracted to assist us in providing such Platform. In addition, Non-Personal Information in aggregated, anonymous form may be shared with third parties who assist us with our internal operations such as administration, analytics, research, strategy and optimization. The third parties we contract with for the foregoing purposes (“Platform Providers”) will be authorized to use such Information only for the purposes for which the party was engaged; however, please understand that the storage and use of your Information by such Platform Providers is not in our control.

Our Platform may offer social sharing features such as “Share” or “Like” on Facebook or other third party social networking sites. If you decide to use such features, it may allow the sharing and collection of Information both to and from such third-party social networks. You should visit the policies of such third parties for more information about their information collection practices.

We may disclose your Personal Information or other Information collected if required by law or court order, if the information relates to actual or threatened harmful conduct, to investigate and/or take action against illegal activity, suspected abuse or unauthorized use of the Platform, or to protect the property or safety of others.

In connection with any sale or transfer of our company or any line of business (including the assets relating thereto), customer information generally is one of the transferred business assets, and such customer information (including your Personal Information) will be transferred or sold to the acquirer or transferee.

Advertising

By using our Platform, you may be offered advertising content. We or the ad networks we use may utilize ad-serving technologies that use cookies, web beacons, tracking pixels and other technologies that are placed within the ads and allow us or our networks to collect Non-Personal Information. Non-Personal Information such as age and gender may be used to ensure that appropriate advertising is offered to you. Usage Data and Non-Personal Information such as advertising identifiers may be used to determine how many clicks an ad received, to measure the effectiveness of ad campaigns, to determine the proper amount of repeat views of a given ad, and/or to deliver ads that best relate to your interests. Depending on your device and its operating system, you may be able to choose to prevent your device's ad identifier being used for interest- based advertising or reset your device's ad identifier by changing the settings of your device.

Your Rights

We ask that you keep the Personal Information that you provide to us current and that you correct any information you have provided us by contacting us at privacy@versyv.com. You represent and warrant that all Personal Information you provide us is true and correct and relates to you and not to any other person.

If you wish to opt out of further communications from us, or if you wish to review, delete and/or

90111-00002/2550656.1

revise the Personal Information we have stored about you, please contact us with your specific request at privacy@versyv.com; provided, however, that we reserve the right to retain an archive of such Personal Information for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such information.

You may have the ability to decline to permit cookies or other tracking technology, but in that case we cannot promise you that all features will function properly as a result.

If you use the Platform, you are responsible for maintaining the confidentiality of your account and for restricting access to your computer or device, and you agree to accept responsibility for all activities that occur under your account.

Children and Minors

We do not knowingly collect or use any Personal Information from minors under the age of 13. If we collect Personal Information from someone we learn to be under 13 years of age, such Personal Information shall immediately be deleted. If you are a parent or guardian of a child under 13 years of age and you believe your child has provided us with Personal Information, please contact us at privacy@versyv.com.

If you are a California resident under the age of 18, and a registered user of our Platform, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to privacy@versyv.com and include “CA Removal Request” in the subject line. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Changes

We reserve the right to change this Privacy Policy at any time. In the event we make material changes to this Privacy Policy, such policy will be re-posted in the "Privacy" section of our Platform with the date such modifications were made indicated on the top of the page. Therefore, please review this Privacy Policy from time to time so that you are aware when any changes are made to this Privacy Policy. If you have any questions about the changes that were implemented, please contact us at privacy@versyv.com and include “Information Regarding Updated Policy” in the subject line. In any event, your continued use of the Platform after such change constitutes your acceptance of any such change(s), and if you do not accept any changes, you may choose not to use the Platform or opt out by sending us an appropriate notice.

Security

It is entirely your choice whether or not you provide Personal Information to us. We have put in place physical, electronic, and managerial procedures to attempt to safeguard and help prevent unauthorized access, maintain data security, and correctly use the Personal Information collected

90111-00002/2550656.1

through the Platform. We take, or obligate applicable third parties to take, reasonable precautions to protect our customers' Personal Information against loss, misuse, unauthorized disclosure, alteration, and destruction. However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any information that you transmit to us or from us, and you do so at your own risk. We cannot ensure or warrant the security of any information you transmit to us by email and you do so at your own risk.

If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at privacy@versyv.com.

Your California Privacy Rights

Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California customer, a business may be required to provide detailed information regarding how that business has shared that customer’s personal information with third parties for direct marking purposes. However, the foregoing does not apply to businesses like ours that either do not disclose Personal Information to third parties for direct marketing purposes without prior approval or give customers a free mechanism to opt out of having their personal information disclosed to third parties for their direct marketing purposes (for more detail on our policy, please see the first bullet point in the Section above entitled “Disclosure of the Information That We Collect”). California users may request further information about their rights under this law and our policy by writing to us at privacy@versyv.com, using the subject line “CA Request for Information,” and requesting further information.

California Do Not Track Disclosures: because we respect your privacy, we will abide by any “do not track” technology that you may choose to utilize, although, as described above with cookies, such technology may negatively affect the functionality of the Platform.

Third Party Links

Our Platform may contain links to other sites on the Web. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave the RiddleVerse platform and to read the privacy statements of each and every Web site that collects personally identifiable information. This privacy policy applies solely to information collected on the RiddleVerse platform.

Legal Disclaimer

Our Platform operates AS-IS, and we do not represent or warrant that our Platform will be available at all times, or that your use of the Platform will be uninterrupted or error-free. We are not responsible for your ability to access the Platform or for matters beyond our control. This Privacy Policy is governed by California law, excluding its provisions on choice of law.

90111-00002/2550656.1

If you have any general questions about our Privacy Policy, please contact us at privacy@versyv.com.

90111-00002/2550656.1