Dhouse – Skill-Based Gaming Platform

Head-to-Head Competitive Matches for Monetary Prizes

Operated by CLAN Holdings LLC

This Privacy Policy (“Policy”) explains how CLAN Holdings LLC (“Dhouse,” “we,” “us,” or “our”) collects, uses, stores, shares, and protects personal information when you access or use the Dhouse platform, including all associated mobile applications, websites, APIs, and related services (collectively, the “Platform”). Dhouse is a skill-based competition platform that enables users to enter head-to-head (1v1) video game matches for monetary prizes. Because match outcomes involve real money and require objective verification, Dhouse collects a broader range of personal information than a typical gaming or entertainment application. This Policy describes each category of data we collect, the specific purposes for which it is used, the parties with whom it may be shared, and the rights you have over your data. This Policy applies to all registered users, prospective users, and visitors to the Platform, regardless of location. Where applicable, this Policy addresses obligations under the California Consumer Privacy Act (CCPA), the General Data Protection Regulation (GDPR), the UK GDPR, Canada’s PIPEDA, and other relevant privacy and data protection laws.

1. Company Information and Data Controller Identity

The entity responsible for processing your personal information is: CLAN Holdings LLC Attn: Privacy Officer

Harrisonville, MO 64701 Privacy & Data Protection: Support@dhousegames.com General Support: Support@dhousegames.com Legal & Compliance: Support@dhousegames.com Website: dhousegames.com For users located in the European Economic Area (EEA) or the United Kingdom (UK), Dhouse acts as the “Data Controller” as defined under the GDPR and UK GDPR respectively. This means we determine the purposes and means by which your personal information is processed. All formal data subject requests, privacy complaints, and rights exercise submissions should be directed to Support@dhousegames.com.

2. Scope, Applicability, and Third-Party Exclusions

2.1 Who This Policy Applies To

This Policy applies to:

• -All registered users who have created an account and participate in paid matches
• -Prospective users who browse the Platform or initiate registration without completing it
• -Users who undergo identity verification (KYC) processes
• -Users who submit gameplay recordings or stream matches for verification purposes
• -Anyone who contacts Dhouse via support, dispute, email, or legal channels in connection with the Platform

2.2 What This Policy Does Not Cover

This Policy does not govern the data practices of the following third-party entities, each of which operates under its own independent privacy policies:

• -Game Developers and Publishers: The video game titles you play in connection with Dhouse matches, including but not limited to titles published by Activision, Epic Games, Riot Games, EA Sports, Ubisoft, or any other developer, are governed by those developers’ own privacy policies and end user license agreements (EULAs). Dhouse has no control over the data those developers collect about your in-game activity.
• -Payment Processors: When you deposit funds or receive payouts via PayPal, bank transfer, or digital wallet, those transactions are processed and governed by the privacy policies of those payment providers. Dhouse receives only the minimum information necessary to confirm transaction completion.
• -Third-Party Login Providers: If you use a third-party login (e.g., Google or Apple ID), that provider’s data practices are governed by their own policies.
• -Linked Streaming Platforms: If you link a Twitch, YouTube, or other streaming account, that platform’s own data collection practices are independent of this Policy.

2.3 Consent

By creating an account, completing KYC verification, entering a match, or submitting a gameplay recording, you consent to the collection, use, and processing of your personal information as described in this Policy. Where consent is the legal basis for specific processing activities, you may withdraw it at any time by contacting Support@dhousegames.com, without affecting the lawfulness of processing carried out prior to withdrawal.

3. Personal Information We Collect

The following describes every category of personal information we collect, how it is obtained, and why it is necessary for the operation of the Platform. Due to the real-money and competitive nature of the Platform, some of these categories are more sensitive than those collected by a typical consumer application.

3.1 Account and Identity Information

When you register for an account, you provide:

• -Full legal name
• -Username or display name, including PSN ID (PlayStation Network ID)
• -Email address
• -Phone number (where provided or required for account verification)
• -Date of birth (may be required to verify that you meet the minimum age requirement of 18 years)
• -Country and state/province of residence
• -Account password (stored exclusively in hashed, salted, encrypted form; we never store or have access to your plaintext password)

3.2 Identity Verification (KYC) and Tax Data

To comply with anti-money laundering (AML) regulations, prevent fraud and underage participation, and fulfill financial reporting obligations, users who enter paid matches or request prize withdrawals must complete identity verification. This process requires:

• -Government-issued photo identification: A clear, legible copy of your passport, national identity card, or driver’s license, including your full name, photograph, date of birth, and document number.
• -Selfie or live photo: A real-time or recent photograph of your face used for biometric comparison against your submitted ID document to confirm you are the document’s legitimate holder.
• -Proof of address: A recent (within 90 days) utility bill, bank statement, or equivalent document confirming your residential address, where required by applicable AML regulations.
• -Tax identification information: Your Social Security Number (SSN), Individual Taxpayer Identification Number (ITIN), Employer Identification Number (EIN), or international equivalent, collected where your cumulative annual winnings meet or exceed applicable IRS or international tax reporting thresholds (e.g., $600 USD in the United States requiring IRS Form 1099-MISC issuance).
• -KYC verification is conducted by a qualified third-party identity verification provider (e.g., Persona, Jumio, or equivalent). Dhouse does not store full raw copies of government ID documents beyond the minimum period required to complete verification. All retained verification records are stored in AES-256 encrypted form with strict role-based access controls. Only personnel directly involved in compliance and fraud investigation may access raw KYC documents.

3.3 Gameplay and Competition Data

Gameplay data is central to how Dhouse verifies match integrity and ensures fair competition. We collect:

• -Gameplay Recordings (Video/Audio): Full-length video recordings of your match submitted for verification. These recordings may incidentally capture your voice, background audio, in-game chat, ambient sounds, or other audio occurring during the recording session. This audio is not intentionally collected or analyzed for non-verification purposes.
• -Screenshots and Result Images: Static screenshots of in-game result screens, score summaries, or end-of-match statistics submitted as supporting evidence.
• -File Metadata: Technical properties of submitted files, including timestamps, file size, resolution, frame rate, encoding format, and device or software information embedded in the file, used to assess recording authenticity and detect potential tampering.
• -In-Game Performance Metrics: Match results, scores, kill/death/assist ratios, placement, accuracy statistics, round results, and other game-specific outcome indicators extracted from submitted recordings or API-verified game data.
• -Match History: A complete record of your match participation history on the Platform, including games played, results, prize winnings, and any integrity flags or moderation actions associated with specific matches.
• -Streaming Data: If you are required to or choose to stream your match via Twitch, YouTube, or another linked streaming platform, we collect the stream URL, stream ID, and stream metadata (timestamps, viewer count) for verification purposes. We do not independently record or archive your stream; the stream is monitored and reviewed on the relevant streaming platform.

3.4 Device and Technical Information

We automatically collect the following technical data when you access or use the Platform:

• -IP Address: Your internet protocol address, used for approximate geolocation, fraud detection, multi-account detection, and enforcement of geographic access restrictions.
• -MAC Address: The hardware identifier of your network adapter, collected as part of our device fingerprinting and anti-cheat procedures to detect unauthorized software or multiple accounts operating from the same device.
• -Device Identifier: A unique identifier assigned to your device (e.g., advertising ID, device fingerprint), used for fraud detection and ban enforcement.
• -Browser or Application Data: Browser type and version, or app version if you use a mobile application, along with session identifiers and navigation logs.
• -Error Logs and Crash Reports: Technical logs generated when the Platform or mobile application experiences errors, used to diagnose and resolve technical issues.

3.5 Anti-Cheat and Process Data

To maintain the integrity of competitions and detect the use of prohibited cheating tools, Dhouse may collect the following data from your device during active match sessions:

• -Running Process Data: A list of software processes actively running on your device at the time of match entry or during match play, used to detect the presence of known cheat software, aimbots, script executors, macro programs, or other prohibited tools.
• -Active Window Data: Information about which application or window is currently in focus on your device, used to verify that you are actively engaged in the game and not using prohibited overlay tools.
• -Peripheral and Input Device Data: Information about connected peripherals (e.g., mouse model, keyboard type) that may be relevant to detecting unauthorized hardware-based cheating tools.
• -The collection of process and device data for anti-cheat purposes is limited to the information strictly necessary to detect prohibited tools. We do not access, read, copy, or transmit the contents of any personal files, documents, messages, or applications on your device. Our anti-cheat data collection is limited to process names, window titles, and peripheral identifiers. You will be informed prior to any match session if anti-cheat monitoring is active.

3.6 Financial Information

To process match entry fees, manage platform wallets, and distribute prize payouts, we collect:

• -Transaction Records: A complete history of all entry fees paid, deposits made, prize winnings earned, payouts requested, and payouts distributed through your Platform account.
• -Wallet Balance: Your current available Platform wallet balance.
• -Tokenized Payment Method Details: Where you have saved a payment method for future deposits, we store only the tokenized representation provided by our payment processor (e.g., the last four digits of a card number and card type, or a PayPal account email address). We do not store full card numbers, CVV codes, or complete bank account details on our servers.
• -Payout Account Details: Your designated payout method (e.g., PayPal email address, bank account number and routing number, or digital wallet identifier) required to distribute prize winnings.
• -Tax Documentation: Copies of submitted W-9, W-8BEN, or equivalent tax forms, retained as required by applicable tax law.

3.7 Communications and Support Data

• -Content of messages, disputes, appeals, complaints, or inquiries submitted to our support or legal teams
• -Match dispute submissions, including any evidence, recordings, or documentation you provide in connection with a contested match result
• -Correspondence history with Dhouse support staff, including ticket numbers and resolution records
• -Responses to surveys, feedback forms, or user research participation

3.8 Public Profile Data

Certain aspects of your Platform profile are visible to other registered users by default, including:

• -Your username or display name (including PSN ID)
• -Your public match history and win/loss record
• -Your position on public leaderboards, where applicable
• -You may be able to adjust the visibility of certain profile elements through your account privacy settings. However, some information, such as your username and match participation history, is necessary for the competitive integrity of the Platform and cannot be made fully private.

4. Gameplay Recordings – Detailed Policy

4.1 Purpose and Legal Basis for Recording Collection

Gameplay recordings are a foundational operational requirement of the Dhouse Platform. Because real money is distributed based on match outcomes, we have a legal, contractual, and ethical obligation to verify that submitted results are accurate and that no cheating, manipulation, or fraud has occurred. Recordings serve as the primary evidentiary basis for match result verification, dispute resolution, and integrity enforcement. The legal basis for collecting and processing gameplay recordings is:

• -Contractual Necessity: Collection is necessary to perform the match verification services described in our Terms of Service.
• -Legitimate Interests: Processing is necessary to protect the integrity of competitive outcomes and the financial interests of all honest participants on the Platform.
• -Legal Obligation: Retention of recordings associated with financial disputes may be required under applicable consumer protection and financial services laws.

4.2 Audio Content Within Recordings

Gameplay recordings submitted to Dhouse may incidentally capture audio content, including:

• -Your voice or the voices of others present in your recording environment
• -In-game voice chat from other players participating in the match
• -Background ambient sounds, music, or conversations in your recording environment
• -In-game audio events (sound effects, music, announcer audio)
• -This audio is not intentionally solicited and is not separately analyzed, transcribed, or processed for any purpose other than reviewing the recording as a whole in connection with match verification. We do not use incidental audio to build voice profiles, conduct voice recognition, or identify individuals. Where technically feasible, we encourage users to mute non-game audio sources during recording to minimize incidental capture of personal audio.

4.3 Consent to Submission and Verification

By entering any match that requires gameplay verification, you expressly consent to:

• -Submitting a valid Twitch video link (or other approved gameplay verification link) within the designated submission window specified by Dhouse.
• -Making your gameplay recording available for review through Twitch or another approved third-party platform in accordance with the applicable platform's terms, policies, and retention practices.
• -The collection, storage, and processing of the submitted video URL, match-related metadata, and verification records by Dhouse for purposes of match administration, fraud prevention, dispute resolution, and platform integrity.
• -The automated analysis of submitted gameplay content and related information using Dhouse's verification, fraud detection, and integrity monitoring systems.
• -Review of submitted gameplay content by authorized Dhouse personnel in connection with match verification, participant complaints, disputes, fraud investigations, or integrity reviews.
• -The retention of submitted video URLs, verification records, complaint records, and investigation materials for the periods reasonably necessary to administer the match, resolve disputes, comply with legal obligations, and protect the integrity of the Platform.
• -Users acknowledge that gameplay recordings are hosted and retained by Twitch or another approved third-party platform, not by Dhouse, and that the availability of such recordings may be subject to the applicable third-party platform's policies, retention periods, and technical limitations. Dhouse is not responsible for the removal, expiration, unavailability, or deletion of gameplay recordings by any third-party platform.

4.4 Recording Integrity and Authenticity

All submitted recordings are subject to automated and manual authenticity analysis. We assess recordings for indicators of tampering, including but not limited to:

• -Video compression artifacts inconsistent with native capture
• -Inconsistent timestamps, frame rates, or encoding signatures
• -Discrepancies between in-game performance metrics visible in the recording and API-verified game data
• -Evidence of screen recording overlays, editing software watermarks, or post-production modifications
• -File metadata inconsistencies suggesting the recording was modified after initial capture
• -Submission of altered, fabricated, or non-compliant recordings constitutes a material violation of our Terms of Service and will result in match disqualification, forfeiture of entry fees and any associated winnings, and may result in permanent account termination.

4.5 No Unauthorized Use of Recordings

Dhouse will not use your gameplay recordings for any purpose outside of match verification, dispute resolution, fraud investigation, anti-cheat research, and platform integrity enforcement, except with your separate, explicit, and informed consent. Specifically:

• -We will never sell your gameplay recordings to any third party.
• -We will never use your gameplay recordings to train, develop, or improve any artificial intelligence or machine learning system without your explicit opt-in consent.
• -We will never use your gameplay recordings in marketing, advertising, promotional materials, or public-facing content without your separate, written consent obtained through a clearly marked opt-in process.

5. Legal Basis for Processing (EEA and UK Users)

For users in the European Economic Area (EEA) or the United Kingdom (UK), the GDPR and UK GDPR require us to identify a lawful basis for each processing activity. Our legal bases are as follows:

5.1 Contractual Necessity (Article 6(1)(b) GDPR)

Processing is necessary to perform the contract between you and Dhouse (i.e., to provide the Platform services described in our Terms of Service). This covers:

• -Account creation, authentication, and management
• -Match entry processing and wallet management
• -Identity and age verification for paid match eligibility
• -Gameplay recording collection and result verification
• -Prize payout processing and distribution
• -Customer support and dispute resolution

5.2 Legal Obligation (Article 6(1)(c) GDPR)

Processing is necessary to comply with legal obligations applicable to Dhouse, including:

• -Anti-money laundering (AML) and Know Your Customer (KYC) obligations
• -Tax identification and income reporting requirements (e.g., IRS Form 1099-MISC in the U.S.)
• -Responding to lawful requests from courts, regulatory authorities, or law enforcement
• -Compliance with financial record retention requirements
• -Geographic access restriction compliance

5.3 Legitimate Interests (Article 6(1)(f) GDPR)

Processing is necessary for our legitimate interests, or those of third parties, provided those interests are not overridden by your rights. Legitimate interests include:

• -Detecting, preventing, and investigating fraud, cheating, match-fixing, and platform abuse
• -Protecting the financial interests of honest participants through match integrity enforcement
• -Maintaining platform security, including anti-cheat monitoring and multi-account detection
• -Analyzing aggregate usage patterns to improve Platform performance, stability, and user experience
• -Enforcing our Terms of Service and protecting Dhouse’s legal rights

5.4 Consent (Article 6(1)(a) GDPR)

Where we rely on consent as the legal basis, this applies to:

• -Non-essential analytics cookies and tracking technologies
• -Use of gameplay recordings for marketing, promotional, or AI training purposes (requiring separate opt-in)
• -Any additional processing not covered by the bases above, which will be clearly disclosed at the point of consent collection
• -You may withdraw consent at any time by contacting Support@dhousegames.com. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

6. How We Use Your Information

We use the personal information described in Section 3 exclusively for the purposes set out below. We do not use your data for any purpose incompatible with the purposes for which it was collected without providing you with prior notice and, where required, obtaining your consent.

6.1 Platform Operation and Match Delivery

• -Creating, managing, and authenticating user accounts and login sessions
• -Facilitating player matchmaking based on game title, skill level, and match format
• -Processing match entry fees and managing Platform wallet balances
• -Receiving, storing, and analyzing gameplay recordings to verify match results
• -Determining match winners based on objective performance metrics and distributing prize payouts
• -Providing customer support, dispute resolution, and match appeals processing

6.2 Identity Verification and Fraud Prevention

• -Verifying the identity, age, and geographic eligibility of users prior to authorizing participation in paid matches or prize withdrawals
• -Conducting AML and KYC screening as required by applicable financial regulations
• -Detecting and preventing fraudulent chargebacks, multi-accounting, match-fixing, and cheating through device fingerprinting, IP analysis, and behavioral pattern monitoring
• -Investigating reports of prohibited conduct and enforcing Terms of Service violations
• -Flagging high-risk accounts for enhanced review and, where warranted, temporary or permanent suspension

6.4 Financial Processing and Tax Compliance

• -Processing outgoing prize payments via PayPal, bank transfer, or digital wallet
• -Maintaining accurate transaction records for accounting, auditing, and regulatory purposes
• -Generating and issuing tax documentation (e.g., IRS Form 1099-MISC) to users who receive reportable prize income
• -Complying with financial reporting obligations imposed by applicable law, including backup withholding where required

6.5 Platform Security and Integrity

• -Monitoring the Platform for security threats, unauthorized access attempts, and abuse
• -Enforcing geographic access restrictions using IP address geolocation data
• -Detecting and blocking VPN, proxy, or Tor usage used to circumvent access restrictions
• -Conducting periodic audits of match results for systemic anomaly detection

6.6 Analytics and Platform Improvement

• -Analyzing aggregate, de-identified usage data to understand how users interact with Platform features
• -Using tools such as PostHog or equivalent analytics platforms to identify usability issues and prioritize feature development
• -Monitoring Platform performance metrics, error rates, and system stability
• -Conducting internal research to improve matchmaking algorithms and result verification accuracy

6.7 Communications

• -Sending transactional communications, including match confirmation emails, payout notifications, KYC status updates, and account security alerts
• -Notifying users of material changes to the Platform, Terms of Service, or this Privacy Policy
• -Responding to support inquiries, disputes, and appeals

6.8 What We Do Not Do With Your Data

We do not:

• -Sell, rent, trade, or license your personal information to third-party advertisers, data brokers, or marketing organizations.
• -Use your personal data, gameplay recordings, or match history to train generative AI models or machine learning systems without your explicit opt-in consent.
• -Build behavioral advertising profiles based on your Platform activity or target you with interest-based advertising.
• -Share your government-issued identity documents or tax identification numbers with any party other than our KYC provider and applicable tax authorities as required by law.

7. Data Sharing and Disclosure

We do not sell your personal information for monetary or other valuable consideration. We share personal data only to the extent strictly necessary for the purposes described below, and only with parties who are bound by appropriate data protection obligations.

7.2 Payment Processors and Financial Services

We share the minimum necessary financial information with third-party payment processors to facilitate match entry deposits and prize payout distributions:

• -PayPal: For prize payouts distributed to user PayPal accounts. PayPal receives your PayPal account email address and the payout amount.
• -ACH / Bank Transfer Providers: For direct deposit payouts. Your bank account number and routing number (or IBAN/SWIFT equivalent) are transmitted to our banking partner to initiate the transfer.
• -Digital Wallet Providers: For applicable wallet-based payouts.
• -Card Payment Processors: For processing match entry fee deposits made by credit or debit card. Card data is processed directly by our PCI-DSS compliant payment processor; Dhouse receives only a tokenized reference and the last four digits.

7.3 Tax and Regulatory Reporting Authorities

Where required by applicable law, we share your personal and financial information with tax authorities, including:

• -The U.S. Internal Revenue Service (IRS): For users whose cumulative annual prize winnings meet or exceed the applicable 1099-MISC reporting threshold (currently $600 USD per tax year in the United States). We will issue you a copy of any tax form filed on your behalf.
• -Equivalent international tax authorities: For users in jurisdictions with comparable prize income reporting obligations.

7.4 Anti-Cheat and Platform Integrity Partners

We may share de-identified or aggregated cheat tool signatures, device fingerprint patterns, or abuse indicators with industry anti-cheat organizations or game developer partners to improve cross-platform cheating detection. We do not share personally identifiable information with these partners without your consent, except where required by applicable law.

7.5 Analytics Providers

We may use analytics platforms to monitor aggregate Platform performance and user behavior patterns. Analytics providers process data under data processing agreements and are prohibited from using Platform data for their own independent commercial purposes. We configure our analytics tools to minimize the collection of personally identifiable information and to anonymize or pseudonymize data where possible.

7.6 Public Leaderboards

Your username and match performance statistics (win/loss record, prize totals, ranking) may be displayed on public leaderboards accessible to all Platform users. By participating in matches, you acknowledge and consent to the public display of this information. If you wish to opt out of public leaderboard display, please contact Support@dhousegames.com to discuss available options.

7.7 Legal Requirements and Law Enforcement

We may disclose your personal information to courts, law enforcement agencies, regulatory bodies, or governmental authorities where required by applicable law or legal process, including:

• -Compliance with a valid court order, subpoena, search warrant, or regulatory demand
• -Responding to lawful requests from law enforcement in connection with suspected financial fraud, money laundering, underage gambling, or other criminal activity
• -Protecting the rights, property, and safety of Dhouse, its users, and the public
• -Preventing or addressing suspected violations of our Terms of Service that may also constitute criminal conduct
• -Where legally permissible and practically feasible, we will notify you before complying with a law enforcement request, so that you may seek appropriate legal protection.

7.8 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or substantially all assets of Dhouse, your personal information may be transferred to the acquiring entity or successor organization as part of the transaction. We will notify registered users via email or a prominent Platform notice prior to any such transfer taking effect, and you will be informed of any material changes to this Policy that result from the transaction.

7.9 Aggregated and De-Identified Data

We may share aggregated, anonymized, or de-identified data, which cannot reasonably be used to identify you, with research institutions, game publishers, esports organizations, or publicly, for purposes such as publishing Platform statistics, advancing fair-play research, or contributing to industry anti-cheat efforts. This sharing does not constitute disclosure of personal information.

8. International Data Transfers

8.1 Primary Processing Jurisdiction

Dhouse is headquartered and primarily operates in the United States. All personal information collected through the Platform is processed and stored on servers located in the United States. If you access the Platform from outside the United States, including from the EEA, UK, Canada, Australia, or other jurisdictions, your personal information, including identity documents, financial data, and gameplay recordings, will be transferred to and processed in the United States, where privacy laws may differ from those in your home country and may not provide the same level of protection.

8.2 Safeguards for EEA and UK Transfers

For transfers of personal data from the EEA or UK to the United States, we rely on appropriate legal transfer mechanisms as required by the GDPR and UK GDPR, including:

• -Standard Contractual Clauses (SCCs) approved by the European Commission, incorporated into our agreements with all relevant data processors and service providers receiving personal data from EEA/UK users.
• -Where applicable, adequacy decisions or equivalent frameworks recognized by the European Commission or UK Information Commissioner’s Office (ICO).
• -Copies of applicable Standard Contractual Clauses are available upon written request to Support@dhousegames.com.

8.3 Transfers Involving Service Providers

Some of our service providers, including KYC vendors, payment processors, and analytics tools, may operate data centers in multiple jurisdictions. We contractually require all such providers to implement appropriate safeguards for international data transfers and to comply with applicable data protection laws in all jurisdictions where they process your data.

9. Data Retention Policy

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, to comply with legal and regulatory obligations, to resolve disputes, and to enforce our agreements. Due to Dhouse’s status as a real-money platform subject to AML, KYC, and tax reporting requirements, some retention periods are longer than those of a standard consumer application.

9.1 Active Accounts

All personal information associated with an active account is retained for the full duration of your account’s active life, plus a post-closure retention period as described in Section 9.2.

9.2 Retention Periods by Data Category

• -Account Registration Data (name, email, username, date of birth): Retained for the duration of the account and for a minimum of two (2) years following account closure, to prevent ban evasion, facilitate re-registration verification, and support any post-closure dispute or legal claim.
• -Identity Verification / KYC Documents (government ID, selfie, proof of address): Retained for a minimum of five (5) years from the date of successful verification, or longer as required by applicable AML/KYC regulations. This period reflects standard financial services record-keeping obligations.
• -Tax Identification and Reporting Records (SSN/TIN, W-9/W-8BEN forms, 1099-MISC copies): Retained for a minimum of seven (7) years from the date of issuance or filing, as required under U.S. federal tax law and equivalent international requirements.
• -Financial Transaction Records (entry fees, deposits, payouts, wallet history): Retained for a minimum of seven (7) years from the date of the transaction, consistent with standard accounting and financial audit requirements.
• -Gameplay Recordings (video evidence): Retained for a minimum of sixty (60) days following match completion to allow the dispute submission window to close. Recordings associated with active disputes, fraud investigations, or legal proceedings are retained for the duration of such proceedings plus one (1) additional year after final resolution.
• -Anti-Cheat Process Data: Retained for a minimum of ninety (90) days following collection. Data associated with confirmed integrity violations is retained for five (5) years to support ban enforcement and prevent re-registration.
• -Device and Technical Data: Retained in identifiable form for up to twenty-four (24) months; thereafter aggregated or permanently anonymized.
• -Support and Dispute Communications: Retained for a minimum of five (5) years to support dispute resolution, legal proceedings, and regulatory inquiries.

9.3 Account Closure and Deletion

You may request closure of your account at any time by contacting Support@dhousegames.com or using the account closure feature within the Platform, if available. Upon receipt of a verified closure request, we will:

• -Deactivate your account and remove it from active platform systems within five (5) business days
• -Permanently delete or irreversibly anonymize personal identifiers (name, email, password) within thirty (30) days, subject to the legal retention obligations described in Section 9.2
• -Confirm completion of the deletion process via email to the address associated with your account
• -Account closure does not extinguish any pre-existing financial obligations, pending disputes, or tax liabilities. Legally required records will be retained for their mandated periods regardless of account closure. Any Platform wallet balance remaining at the time of account closure will be processed for withdrawal through our standard verification procedures, subject to any applicable holds or compliance checks.

10. Your Privacy Rights

Depending on your location and the applicable privacy framework, you have specific legal rights with respect to your personal information. We are committed to honoring these rights in good faith, subject to applicable legal limitations and retention obligations specific to the Platform’s real-money and regulatory environment.

10.1 Right to Access / Right to Know

You may request confirmation of whether we hold personal information about you, and if so, a copy of that information along with details about how it is used and shared. California residents may additionally request disclosure of the specific categories and pieces of personal information we have collected, the categories of sources, and the business purposes for collection, consistent with CCPA requirements.

10.2 Right to Correction/Rectification

If any personal information we hold about you is inaccurate or incomplete, you may request correction. Some account information (e.g., display name, email address) may be updated directly through your profile settings. Corrections to identity verification records or financial data require contacting our support team directly, as changes to such records may trigger re-verification requirements.

10.3 Right to Erasure/Right to Be Forgotten

You may request deletion of your personal information. However, this right is subject to significant limitations in the Dhouse context due to our legal obligations:

• -Financial transaction records must be retained for a minimum of seven (7) years under applicable tax and financial services law, regardless of your deletion request.
• -KYC and identity verification records must be retained for a minimum of five (5) years under AML regulations.
• -Records associated with confirmed Terms of Service violations (e.g., cheating or fraud) may be retained indefinitely to prevent re-registration and protect Platform integrity.
• -Gameplay recordings associated with unresolved disputes cannot be deleted until final dispute resolution.
• -Aggregated, anonymized data that cannot reasonably be re-linked to you may be retained indefinitely.

10.4 Right to Restriction of Processing

In certain circumstances (e.g., while a rectification request is being assessed, or while you have lodged an objection), you may request that we restrict processing of your data to storage only. Please note that restrictions on fraud detection or KYC processing may affect your ability to participate in paid matches during the restriction period.

10.5 Right to Data Portability

Where processing is based on consent or contract and is carried out by automated means, you have the right to receive a structured, commonly used, and machine-readable copy of the personal data you have provided to us. You may transmit this data to another controller where technically feasible.

10.6 Right to Object

Where we rely on legitimate interests as the legal basis for processing, you have the right to object at any time. We will cease the relevant processing unless we can demonstrate compelling legitimate grounds that override your interests, or the processing is necessary for the establishment, exercise, or defense of legal claims.

10.7 Rights Under State Privacy Laws (U.S. Residents)

Residents of California (CCPA/CPRA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), and other states with applicable privacy legislation have rights including those described above, as well as:

• -California Residents: The right to opt out of the “sale” or “sharing” of personal information. We do not sell personal information as defined under the CCPA. If our practices change, we will provide a “Do Not Sell or Share My Personal Information” mechanism.
• -All Applicable States: The right to non-discrimination — we will not deny you access to the Platform, charge different prices, or provide a lower quality of service because you exercised a privacy right.

10.8 How to Exercise Your Rights

To submit a privacy rights request:

• -Email: Support@dhousegames.com
• -Subject line: “Privacy Rights Request – Dhouse”
• -Include: your full name, account username, the specific right you are exercising, and any supporting information
• -We may require identity verification before processing your request to protect against unauthorized access to another user’s data. We will respond within the timeframes required by applicable law: generally thirty (30) days under GDPR; forty-five (45) days under CCPA (with extensions available for complex requests).

10.9 Right to Lodge a Supervisory Complaint

If you are in the EEA or UK and believe we have processed your data in violation of applicable law, you have the right to lodge a complaint with your local data protection supervisory authority. In the UK, this is the Information Commissioner’s Office (ICO) at https://ico.org.uk. In the EU, you may contact the supervisory authority in your country of habitual residence or place of work.

11. Children’s Privacy

11.1 Strict 18+ Requirement

Dhouse is a real-money competitive gaming platform and is strictly and exclusively intended for individuals who are at least eighteen (18) years of age. The Platform is not directed to, and must not be accessed or used by, anyone under the age of eighteen (18) under any circumstances. Unlike many consumer applications that set a minimum age of thirteen (13), our 18+ minimum reflects the real-money nature of our service and applicable legal requirements for skill-based prize competitions.

11.2 Age Verification at Registration and Payout

Our age verification protocols include collection of date of birth at registration, and KYC identity verification (including government-issued photo ID) prior to any paid match entry or prize withdrawal. These verification steps are designed to prevent minors from accessing real-money features of the Platform.

11.3 Response to Discovery of Minor’s Account

If we discover or receive a credible report that a registered user is under the age of eighteen (18), we will immediately:

• -Suspend the account and block all access to Platform features
• -Permanently delete all personal information associated with the account that is not subject to mandatory legal retention
• -Void all match results, entry fees, and any prize winnings associated with the account
• -Notify a parent or guardian if we have contact information available and applicable law requires or permits such notification

11.4 Parental or Guardian Reports

If you are a parent or guardian and believe your child has accessed or registered on Dhouse without your knowledge or consent, please contact us immediately at Support@dhousegames.com with the subject line “Minor Account Report.” Please include your child’s approximate age, the username or email address they may have used, and any additional context. We will investigate and take prompt corrective action upon receipt of a credible report.

12. Security Measures

12.1 Technical Safeguards

Given the sensitivity of the personal information we process, including government identity documents, financial data, tax identification numbers, and gameplay recordings, we implement a comprehensive set of technical security measures:

• -AES-256 encryption for all data at rest, including identity documents, financial records, and gameplay recordings
• -TLS 1.2 or higher (SSL) for all data in transit between client devices and our servers
• -Secure, salted password hashing using industry-standard algorithms (e.g., bcrypt or Argon2); plaintext passwords are never stored or accessible
• -Multi-factor authentication (MFA) options available for user accounts
• -Role-based access controls (RBAC) limiting data access to authorized personnel on a strict need-to-know basis
• -Encrypted, access-controlled document storage for identity verification materials
• -DDoS protection, web application firewall (WAF), and bot mitigation at the infrastructure level
• -Regular security patch management, dependency auditing, and third-party penetration testing

12.2 Organizational Safeguards

• -Access to sensitive user data is granted only to employees and contractors who require it for specific, authorized job functions
• -All staff with access to personal data receive mandatory training on data protection, security protocols, and incident response procedures
• -Third-party service providers undergo security due diligence before engagement and are bound by data processing agreements requiring compliance with applicable security standards
• -Internal incident response procedures are maintained to enable rapid detection, containment, investigation, and notification of security incidents

12.3 Limitations and Breach Notification

Despite our extensive security measures, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security of your personal information. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will:

• -Notify affected users without undue delay and within seventy-two (72) hours where required under the GDPR or other applicable law
• -Notify relevant supervisory authorities and regulatory bodies as required
• -Provide clear guidance on steps you can take to protect yourself following a breach

12.4 Your Security Responsibilities

You play an important role in protecting the security of your account and personal data. You are responsible for:

• -Maintaining the confidentiality of your login credentials and not sharing them with any other person
• -Enabling multi-factor authentication where available
• -Using a strong, unique password not reused from other services
• -Promptly reporting any suspected unauthorized access to your account to Support@dhousegames.com

13. Cookies and Tracking Technologies

13.1 Types of Cookies and Trackers We Use

• -Strictly Necessary Cookies: Essential to Platform functionality, including maintaining your authenticated session, storing security tokens, and enabling core features. These cannot be disabled without preventing you from using the Platform.
• -Security and Fraud Prevention Trackers: Used to detect bot activity, unauthorized access, VPN usage, and suspicious behavioral patterns. These are operationally essential for platform integrity.
• -Anti-Cheat and Multi-Account Detection: Device fingerprinting and browser identification technologies used to detect multiple accounts operated from the same device and to enforce bans.
• -Analytics Cookies: Used to collect aggregate data about how users interact with the Platform (e.g., via PostHog or equivalent). These help us identify usability issues and improve Platform performance.
• -Preference Cookies: Used to remember your Platform settings and preferences across sessions.

13.2 Managing Cookie Preferences

You may control or disable non-essential cookies through your browser’s settings or through any cookie preference center provided on the Platform. Please note that disabling security or anti-cheat tracking technologies may result in your account being flagged for manual review or may prevent access to certain Platform features. Where required by law (e.g., in the EEA and UK), we will present a cookie consent interface upon your first visit to the Platform.

14. AI and Automated Decision-Making

14.1 No AI Training on User Data

As of the Effective Date of this Policy, Dhouse does not use personal data, gameplay recordings, match history, or any other user-generated content to train, fine-tune, evaluate, or develop artificial intelligence models, large language models, computer vision systems, or voice recognition technologies without your explicit opt-in consent.

14.2 Automated Match Verification

Dhouse uses automated systems to analyze submitted gameplay recordings and game data for the purpose of verifying match results and detecting integrity violations. These systems assess objective performance metrics and compare submissions against expected ranges and known anomaly patterns. Where automated systems flag a submission, the matter is escalated to a human reviewer before a final determination is made. For EEA and UK users, where automated match result determination constitutes a decision that produces legal or similarly significant effects, you have rights under GDPR Article 22, including the right to request human review, to express your point of view, and to contest the decision through our internal dispute resolution process.

14.3 Fraud Detection Algorithms

We use automated fraud detection and risk scoring algorithms to identify suspicious activity, including multi-accounting, VPN circumvention, anomalous match patterns, and financial irregularities. Accounts flagged by these systems may be subject to payout holds, additional verification requirements, or suspension pending human review. You may contest any adverse action through our support and appeals process.

15. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, Platform features, or applicable law. When we make material changes, we will:

• -Update the “Last Updated” date at the top of this Policy
• -Post the revised Policy prominently on the Platform
• -Notify registered users of material changes via a pop-up notification within the Platform application and/or via email to the address associated with your account, at least fourteen (14) days before the changes take effect where practicable
• -Material changes include, but are not limited to, changes in how we use gameplay recordings, changes to our data sharing practices, introduction of new categories of data collection, or changes to your privacy rights under this Policy.
• -Your continued use of the Platform after the updated Policy has been posted and you have been notified constitutes your acceptance of the revised Policy. If you do not agree with any changes, you must discontinue use of the Platform and may request account closure as described in Section 9.3. Archived versions of previous Privacy Policies are available upon written request.

16. Contact Us

For any questions, concerns, complaints, or rights exercise requests related to this Privacy Policy or your personal data, please contact our Privacy Officer: CLAN Holdings LLC Attn: Privacy Officer

[Harrisonville, Missouri, 64701] Privacy & Data Protection: Support@dhousegames.com General Support: Support@dhousegames.com Legal & Compliance: Support@dhousegames.com Website: dhousegames.com We aim to acknowledge all privacy-related inquiries within five (5) business days and to provide a substantive response within the timeframes required by applicable law. For general gameplay support or account assistance, please use our in-platform support ticketing system.

Your data powers fair competition. We protect it accordingly.

© CLAN Holdings LLC – Dhouse Platform. All rights reserved.