Privacy Policy

STRYBE PRIVACY POLICY

Effective Date: 9 September 2026

Last Updated: 9 September 2026

Version: 2.1

1. INTRODUCTION

1.1 About This Privacy Policy

Sports Exclusive Pty Ltd ACN 684 430 895 trading as Strybe ("Strybe," "we," "our," or "us") is committed to protecting the privacy and security of your personal information.

This Privacy Policy explains how we collect, use, disclose, store, and protect personal information when you access or use our Platform in accordance with the Privacy Act 1988 (Cth) (as amended by the Privacy and Other Legislation Amendment Act 2024 (Cth)) and the Australian Privacy Principles (APPs). It should be read together with, and forms part of, our Strybe Terms and Conditions, which govern your use of the Platform and are available on the Platform.

1.2 Definitions

In this Privacy Policy:

"Account" means the user profile created by a User to access and utilise the Platform;

"Content" means any and all text, images, videos, audio recordings, graphics, data, information, materials, or other works uploaded, posted, transmitted, or otherwise made available by Users through the Platform;

"Creator" means a User who uploads Content to the Platform and offers subscription-based or paid access to such Content;

"Personal Information" means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not;

"Platform" means the Strybe website, mobile applications, software, services, and all related technology and infrastructure operated by Strybe;

"Privacy Act" means the Privacy Act 1988 (Cth);

"Subscriber" means a User who pays subscription fees or other amounts to access Content provided by Creators on the Platform; and

"User" or "you" means any person or entity that creates an Account, accesses, or uses the Platform in any capacity.

1.3 Acceptance

By creating an Account or using the Platform, you acknowledge that you have read and understood this Privacy Policy. Where required by law, we will obtain your separate express consent for the collection, use, and disclosure of your Personal Information for specific purposes, including direct marketing and the use of cookies and analytics technologies. For direct marketing purposes, we will provide you with a simple means to opt out of receiving such communications in accordance with APP 7. If you do not agree to this Privacy Policy, you must not use the Platform. Your continued use of the Platform following the creation of your Account constitutes acceptance of the practices described in this Privacy Policy, subject to your rights under the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

1.4 Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. We will notify you of material changes by:

(a) posting the revised Privacy Policy on the Platform with a revised "Effective Date" and "Last Updated" date; and/or

(b) sending notice to you via email or through the Platform.

If you do not agree to the revised Privacy Policy, you must cease using the Platform within 30 days of notification. Your continued use of the Platform following notification of material changes constitutes your acceptance of the revised Privacy Policy, provided that where the changes relate to a new purpose for collection, use or disclosure of your Personal Information, or materially expand our rights, we will seek your express consent before implementing such changes.

2. PERSONAL INFORMATION WE COLLECT

2.1 Information You Provide Directly

We collect Personal Information that you voluntarily provide to us when you:

(a) Create an Account, including:

– Full name;

– Email address;

– Username; and

– Where you sign in with Apple or Google, the name, email address (or Apple private relay address), and account identifier that provider shares with us. We do not receive your password for that provider.

Important Note: We do not store your password in plain text. Passwords are securely kept. We cannot access or retrieve your actual password.

(b) Upload Content, including:

– Videos, images, audio files, and text;

– Metadata associated with uploaded Content (e.g., file type, upload date, file size); and

– Captions, descriptions, and tags associated with Content.

– Messages sent through the Platform's messaging features, including paid direct messages and live stream chat;

– Customer support inquiries and correspondence;

– Feedback, reviews, and survey responses; and

– Reports of violations or complaints.

(d) Subscribe to or purchase from Creators, including:

– Subscription preferences;

– Subscription status (active, cancelled, expired); and

– Records of one-off purchases such as post unlocks, gifts, paid direct messages, digital products, and physical products.

(e) Provide payment details:

Important Note: We use third-party payment processors (including Stripe, Apple In-App Purchase, and other payment service providers) to handle payment processing. We do not collect, process, or store any payment information, including payment card details, bank account information, billing addresses, or tax identification numbers (ABN, TFN, etc.). All payment and financial information is collected, processed, and stored directly by our payment processor(s) in accordance with their privacy policies and compliance standards. Our payment processor(s) are responsible for the security and handling of all payment data. We receive from our payment processor(s) only:

– Confirmation of successful or failed transactions;

– Transaction reference identifiers;

– Payment status updates (successful, pending, failed, refunded); and

– Dispute and chargeback notifications.

For more information about how our payment processors handle your payment information, please refer to their respective privacy policies (for example, Stripe's Privacy Policy at https://stripe.com/privacy and Apple's Privacy Policy at https://www.apple.com/legal/privacy).

2.2 Information Collected Automatically

When you access or use the Platform, we automatically collect certain information, including:

(a) Device Information, such as:

– Device type, model, and operating system;

– Browser type and version; and

– Unique device identifiers; and

– Push notification tokens, where you have enabled notifications.

(b) Usage Information, such as:

– Pages visited and features accessed;

– Time and date of visits;

– Duration of Platform usage;

– Click-through rates and navigation paths;

– Search queries entered on the Platform;

– Content viewed, downloaded, or interacted with; and

– Subscription and purchase activity.

– IP address; and

– Approximate geographic location derived from IP address.

(d) Cookies and Tracking Technologies:

– Cookies, web beacons, pixels, and similar tracking technologies;

– Session identifiers; and

– Analytics data.

2.3 Information From Third Parties

We may collect Personal Information about you from third-party sources, including:

(a) Payment Processors: Limited transaction information from our payment processor(s) (such as Stripe and Apple) as described in Section 2.1(e) above, necessary to confirm payments and manage subscriptions.

(b) Analytics and Service Providers: Aggregated and de-identified data about user behaviour and Platform performance from analytics services.

(c) Publicly Available Sources: Information from public databases, social media profiles (if you choose to link your social media accounts), and other publicly accessible sources.

2.4 Sensitive Information

We generally do not collect sensitive information (such as health information, racial or ethnic origin, political opinions, religious beliefs, or sexual orientation) unless:

(a) you voluntarily include such information in Content you upload;

(b) it is necessary for a specific purpose and you have provided explicit consent; or

If you choose to include sensitive information in your Content or communications, we will handle that information in accordance with this Privacy Policy and APP 3, which requires us to obtain your express consent before collecting sensitive information unless an exception applies. By voluntarily including sensitive information in Content you upload, you provide your express consent to our collection, use, and disclosure of that information strictly as described in this Privacy Policy and only to the extent necessary to provide the Platform services. You may withdraw this consent at any time by deleting the relevant Content or contacting us at [email protected], though this will not affect the lawfulness of processing based on consent before its withdrawal. However, we strongly recommend that you do not include sensitive information in any publicly available Content. Once published publicly, sensitive information may be accessed, copied, and further disclosed by third parties beyond our control, and we cannot be responsible for such third-party use. If you choose to make Content containing sensitive information publicly available, you acknowledge and accept these risks.

2.5 Live Streams and Calls

(a) Live Streams are recorded. When a Creator broadcasts a live stream, we record the broadcast, including any chat, voice, or video contributed by participants, and may make the recording available on the Platform as a replay. We retain recordings for moderation, safety, dispute resolution, and legal compliance in accordance with Section 5. By broadcasting, appearing in, or contributing to a live stream you consent to that recording.

(b) Calls are not recorded. We do not record, store, or monitor the content of voice or video calls between Users. We retain only the metadata necessary to operate and bill the call (such as the participants, the scheduled and actual start and end times, and the duration) and any report made by a participant about the call.

2.6 Information Processed by AI Tools

Where a Creator uses the Platform's AI tools, those tools process the Creator's Content, messages, activity, and settings, and may process messages and interactions from Subscribers, in order to produce suggestions or take actions the Creator has enabled. We use this information to operate, evaluate, and improve those tools as described in Section 3. We do not use a Creator's Content to train models that generate content imitating that Creator's identity, likeness, or voice without the Creator's express consent.

3. HOW WE USE PERSONAL INFORMATION

3.1 Primary Purposes

We collect, use, and disclose Personal Information only for purposes that are reasonably necessary for, or directly related to, our functions and activities, in accordance with APP 6. Where we use or disclose your Personal Information for a secondary purpose, we will ensure that purpose is related to the primary purpose of collection and you would reasonably expect such use or disclosure, or we will obtain your consent. The primary purposes for which we collect, use, and process Personal Information are as follows:

(a) Account Management and Service Provision:

– Creating, maintaining, and managing User Accounts;

– Authenticating Users and preventing unauthorised access;

– Providing access to Platform features and functionality;

– Processing subscriptions, one-off purchases, and managing recurring billing; and

– Facilitating the connection between Subscribers and Creators.

(b) Platform Operations and Improvement:

– Operating, maintaining, and improving the Platform;

– Developing new features, products, and services;

– Conducting testing, research, analysis, and product development;

– Monitoring and analysing usage patterns and trends; and

– Troubleshooting technical issues and debugging.

– Displaying and delivering Content to Users;

– Providing content recommendations;

– Managing content libraries and subscriptions; and

– Storing and hosting uploaded Content.

(d) Communication:

– Sending transactional communications (e.g., account confirmations, subscription notifications, password resets);

– Providing customer support and responding to inquiries;

– Sending service announcements and Platform updates; and

– Notifying you of changes to our Terms or Privacy Policy.

(e) Marketing and Promotional Activities:

– Sending promotional emails and newsletters about Platform features and updates, where you have provided express consent to receive such communications or where otherwise permitted by law;

– Notifying you about new Creator content or features that may interest you, where you have provided express consent to receive such communications or where otherwise permitted by law.

You may opt out of receiving marketing communications at any time by using the unsubscribe mechanism in our emails, by updating your account preferences on the Platform, or by contacting us at [email protected].

(f) Safety, Security, and Compliance:

– Detecting, preventing, and investigating fraud, abuse, and illegal activity;

– Enforcing our Terms and Conditions;

– Protecting the rights, property, and safety of Strybe, our Users, and the public;

– Complying with legal obligations, court orders, and regulatory requirements; and

– Responding to lawful requests from government authorities and law enforcement agencies.

(g) Analytics and Performance:

– Conducting analytics to understand Platform usage and User preferences;

– Measuring the effectiveness of our services and features; and

– Creating aggregated, de-identified data for statistical analysis and reporting.

(h) Facilitating corporate transactions such as mergers, acquisitions, or sale of assets, where your Personal Information may be transferred as part of such transaction, subject to the receiving party's agreement to protect your Personal Information in accordance with this Privacy Policy.

(i) AI Tools:

– Generating suggestions, drafts, summaries, and recommendations for Creators;

– Taking actions on a Creator's behalf where the Creator has enabled them;

– Moderating Content and detecting conduct that breaches our Terms; and

– Evaluating and improving the performance and safety of those tools.

(j) Payment Processing and Financial Management:

– Coordinating with our payment processor(s) to process payments, subscriptions, and one-off purchases;

– Calculating and remitting Creator earnings and platform fees;

– Managing subscription billing cycles; and

– Handling refunds, chargebacks, and disputes in coordination with our payment processor(s).

4. HOW WE SHARE PERSONAL INFORMATION

4.1 Information Shared Publicly

Certain information is or may be made publicly visible on the Platform by default or at your discretion, including:

(a) Your username and any profile information you choose to make public;

(b) Content you designate as public or post to public areas of the Platform;

(d) Comments, reviews, and other public contributions.

You acknowledge and agree that any information you choose to make public may be viewed, copied, and used by other Users and third parties outside the Platform. Once information is made public, we cannot control how it is used by others, and it may be difficult or impossible to remove or retrieve. We strongly recommend that you carefully consider what information you choose to make publicly available and avoid including sensitive or confidential information in public Content.

4.2 Information Shared With Other Users

(a) Subscribers and Creators: When you subscribe to or purchase from a Creator, that Creator can see:

– Your username;

– Your subscription or purchase status; and

– Messages you send to them through the Platform.

(b) Messages and Communications: Content shared through the Platform's messaging features is visible to the recipients of those messages. Users should be aware that once messages are sent, Strybe cannot control how recipients use, store, or further share that content.

4.3 Service Providers and Third-Party Partners

We share Personal Information with third-party service providers and partners who perform services on our behalf, including:

(a) Payment Processors (including Stripe, Apple In-App Purchase, and other payment service providers):

– Transaction reference information;

– Subscription and purchase status information; and

– User identifiers necessary to link payments to accounts.

Important: As stated in Section 2.1(e), our payment processor(s) directly collect and store all payment card details, bank account information, and billing addresses. We do not collect, process, or store this information and therefore do not disclose it to our payment processor(s).

(b) Cloud Hosting and Storage Providers (e.g., Amazon Web Services, Google Cloud, or similar):

– Account information;

– Content files and metadata; and

– Usage data necessary for Platform operation.

– Content files for efficient delivery to Users; and

– Geographic location data for optimised content routing.

(d) Customer Support and Communication Tools:

– Contact information;

– Support tickets and correspondence; and

– Account details necessary to provide support.

(e) Analytics and Data Analysis Services (e.g., Google Analytics or similar):

– Usage data and behavioural information;

– Device and browser information; and

– Aggregated and de-identified data.

(f) Email Service Providers:

– Email addresses;

– Communication preferences; and

– Email engagement metrics (open rates, click rates).

(g) Security and Fraud Prevention Services:

– IP addresses;

– Device fingerprints; and

– Activity patterns and security signals.

(h) Identity and Sign-In Providers (Apple and Google):

– Account identifiers and tokens necessary to authenticate you.

(i) Video, Streaming, and Messaging Infrastructure Providers:

– Audio, video, and chat streams during live streams and calls, transmitted in real time; and

– Live stream recordings, for storage and replay.

(j) Artificial Intelligence Service Providers:

– Content, messages, and activity data processed to provide the AI tools described in Section 2.6, under contractual terms that prohibit the provider from using that data to train its own models.

All third-party service providers are contractually required to (and we take reasonable steps to ensure they comply with):

– Use Personal Information only for the specific purposes for which it is provided;

– Implement appropriate security measures to protect Personal Information;

– Comply with the Australian Privacy Principles; and

– Not disclose Personal Information to unauthorised parties.

4.4 Business Transfers

In the event of a merger, acquisition, reorganisation, bankruptcy, or sale of assets, Personal Information may be transferred to the acquiring entity or successor organisation, provided such transfer is reasonably necessary for the transaction and the recipient agrees to handle Personal Information in accordance with this Privacy Policy or provides substantially similar protections. We will provide reasonable notice before your Personal Information is transferred and becomes subject to a different privacy policy, and you will have the opportunity to object to the transfer or delete your Account before the transfer occurs.

4.5 Legal Requirements and Protection of Rights

We may disclose Personal Information where we are required or authorised by or under an Australian law or court/tribunal order. We may also disclose Personal Information where we reasonably believe such disclosure is necessary to:

(a) Comply with applicable laws, regulations, legal processes, or enforceable governmental requests;

(b) Enforce our Terms and Conditions, including investigation of potential violations;

(d) Protect against a serious threat to the life, health or safety of any individual, or to public health or public safety (as permitted under APP 6.2(e)); and

(e) Respond to lawful requests from law enforcement, courts, regulatory authorities, or government agencies.

4.6 Aggregated and De-Identified Data

We may share aggregated, anonymised, or de-identified data that cannot reasonably be used to identify you (and which is therefore not Personal Information under the Privacy Act) with:

(a) Business partners for research and analytics;

(b) Third parties for industry analysis and benchmarking; and

This aggregated data cannot be used to identify individual Users.

4.7 With Your Consent

We may share Personal Information for purposes not described in this Privacy Policy with your explicit consent.

5. DATA RETENTION

5.1 Retention Periods

We retain Personal Information for as long as necessary to fulfil the purposes for which it was collected, including:

(a) Active Accounts: For the duration of your Account's active status and for a reasonable period thereafter;

(b) Deleted Accounts: Following Account deletion, we may retain certain Personal Information for:

– Compliance with legal, tax, accounting, and regulatory obligations as required by Australian law;

– Resolution of disputes and enforcement of agreements;

– Prevention of fraud and abuse; and

– Backup and disaster recovery purposes;

– For as long as the Creator's Account remains active;

– For a reasonable period after Account deletion to fulfil any active subscriptions or resolve disputes; and

– As required by law or legal hold;

(d) Transaction Records: Transaction reference data, subscription records, and purchase records are retained in accordance with tax and financial reporting obligations under Australian law (typically 7 years); and

(e) Communications: Customer support communications and correspondence may be retained for a reasonable period for quality assurance, training, and dispute resolution purposes.

5.2 Deletion and Anonymisation

After the applicable retention period, Personal Information will be:

(a) Permanently and securely deleted from our active systems and backups; or

(b) Anonymised or aggregated such that it can no longer reasonably identify you, in which case it may be retained indefinitely for analytics, research, and business improvement purposes.

5.3 Legal Holds

We may retain Personal Information beyond the standard retention periods where required or authorised by or under an Australian law or a court/tribunal order, or where subject to legal holds, litigation, investigations, or regulatory requests that legally require such retention.

6. DATA SECURITY

6.1 Security Measures

We take reasonable steps to implement and maintain appropriate technical, administrative, and organisational security measures designed to protect Personal Information against misuse, interference, loss, unauthorised access, modification, or disclosure, including:

(a) Encryption:

– Transport Layer Security (TLS) encryption for data transmitted between your device and our servers;

– Encryption of passwords using industry-standard hashing algorithms (bcrypt or similar); and

– Encryption of sensitive data at rest.

(b) Access Controls:

– Role-based access controls limiting employee and contractor access to Personal Information on a need-to-know basis;

– Multi-factor authentication for administrative accounts; and

– Regular access reviews and audits.

– Firewalls and intrusion detection/prevention systems;

– Regular security vulnerability assessments and penetration testing; and

– Security monitoring and incident response procedures.

(d) Secure Development Practices:

– Security-focused software development lifecycle;

– Regular code reviews and security testing; and

– Timely application of security patches and updates.

(e) Physical Security:

– Use of reputable cloud hosting providers with secure data centres; and

– Restricted physical access to infrastructure.

(f) Vendor Management:

– Security assessments of third-party service providers; and

– Contractual security and confidentiality obligations.

(g) Employee Training:

– Regular privacy and security training for employees and contractors; and

– Confidentiality agreements and clear data handling policies.

6.2 Limitations

We implement reasonable security measures as required by APP 11.1 to protect Personal Information from misuse, interference, loss, and from unauthorised access, modification or disclosure. While no method of transmission over the internet or electronic storage is completely secure, we take our security obligations seriously and continuously work to protect your information. You should be aware of the inherent security risks of transmitting information over the internet.

6.3 Your Responsibility

You are responsible for:

(a) Maintaining the confidentiality of your Account credentials;

(b) Using a strong, unique password for your Account;

(d) Restricting access to your devices;

(e) Logging out of your Account after each session, particularly on shared devices; and

(f) Notifying us immediately at [email protected] if you become aware of any unauthorised access to your Account or any security breach. Failure to notify us promptly may limit our ability to investigate and respond to the breach, and may affect your rights under this agreement.

6.4 Data Breach Notification

In the event of an eligible data breach (being a data breach that is likely to result in serious harm to any individual whose personal information is involved in the breach), we will:

(a) Notify affected individuals as soon as practicable after becoming aware of the eligible data breach and in accordance with the requirements of Part IIIC of the Privacy Act and the Notifiable Data Breaches (NDB) scheme;

(b) Notify the Office of the Australian Information Commissioner (OAIC) as required by law;

(c) Provide information about the breach, the types of Personal Information involved, the steps we are taking to mitigate harm, and recommendations about steps individuals can take to reduce the risk of harm; and

(d) Take reasonable steps to contain the breach, mitigate harm, and prevent further unauthorised access.

7. YOUR RIGHTS AND CHOICES

7.1 Access to Personal Information

Under the Australian Privacy Principles, you have the right to request access to the Personal Information we hold about you. To request access:

(a) Contact us at [email protected] with your request;

(b) We will respond to your request within a reasonable timeframe;

(d) We will provide access in a reasonable manner and format;

(e) In certain circumstances permitted by APP 12.3, we may refuse access, including where: providing access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety; providing access would have an unreasonable impact on the privacy of other individuals; the request is frivolous or vexatious; the information relates to existing or anticipated legal proceedings and would not be discoverable; providing access would reveal our intentions in relation to negotiations with you in a way that would prejudice those negotiations; providing access would be unlawful; denying access is required or authorised by or under an Australian law or court/tribunal order; providing access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or we reasonably believe that giving access would be likely to prejudice the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law; the enforcement of laws relating to the confiscation of the proceeds of crime; the protection of the public revenue; or the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct. If we refuse access, we will provide you with written reasons for the refusal (except to the extent it would be unreasonable or unlawful to do so) and information about how you may complain about the refusal.

7.2 Correction of Personal Information

You have the right to request correction of Personal Information that is inaccurate, out-of-date, incomplete, irrelevant, or misleading. To request correction:

(a) Update certain information directly through your Account settings; or

(b) Contact us at [email protected] to request corrections;

(d) If we refuse to correct information, we will provide you with written reasons (except to the extent it would be unreasonable or unlawful to do so) and information about how you may complain about the refusal. Upon your request, we will take reasonable steps to associate with the information a statement that you view it as inaccurate, out-of-date, incomplete, irrelevant or misleading.

7.3 Deletion of Account and Personal Information

You may request deletion of your Account and associated Personal Information at any time:

(a) To delete your Account:

– Log into your Account and navigate to Account settings; or

– Contact us at [email protected] to request Account deletion;

(b) Upon Account deletion:

– Your profile and publicly visible information will be removed from the Platform;

– Your Content will be deleted or made inaccessible to other Users; and

– We may retain certain information as described in Section 5 (Data Retention) where required or authorised by or under an Australian law or court/tribunal order, where we reasonably believe retention is necessary for an enforcement related activity conducted by or on behalf of an enforcement body, for dispute resolution, or to protect against fraud and other illegal activities;

– We may be required or authorised to retain certain information by or under Australian law or a court/tribunal order;

– Information in backups will be permanently deleted in accordance with our backup retention schedules; and

– Aggregated or de-identified data that cannot identify you may be retained indefinitely.

7.4 Marketing Communications Opt-Out

You may opt out of receiving marketing communications from us at any time by:

(a) Clicking the "unsubscribe" link in marketing emails;

(b) Adjusting your communication preferences in your Account settings;

(d) Replying "STOP" to marketing SMS messages (if applicable).

Please note: Even if you opt out of marketing communications, we will still send you transactional and service-related communications that are necessary for your use of the Platform and to fulfil our contractual obligations to you (e.g., subscription confirmations, password resets, important service announcements, billing notifications, and legally required notices).

7.5 Cookie Management

You can control cookies through your browser settings. Most browsers allow you to:

(a) Block all cookies;

(b) Accept only first-party cookies;

(d) Receive notifications before cookies are set.

Please note: Disabling certain cookies may affect Platform functionality and your user experience. Essential cookies that are strictly necessary for the Platform to function cannot be disabled while you are using the Platform, as they are required to provide the service you have requested. If you disable essential cookies, you may not be able to access or use all or part of the Platform.

7.6 Complaints

If you have a complaint about how we handle your Personal Information, you may:

(a) Contact us directly:

Email: [email protected]

We will investigate your complaint and respond within a reasonable period. We will work with you in good faith to resolve the issue.

(b) Lodge a complaint with the OAIC:

If you are not satisfied with our response, you have the right to lodge a complaint with the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner (OAIC)

Website: www.oaic.gov.au

Email: [email protected]

Phone: 1300 363 992

Mail: GPO Box 5218, Sydney NSW 2001

8. COOKIES AND TRACKING TECHNOLOGIES

8.1 What Are Cookies

Cookies are small text files placed on your device by websites you visit. We use cookies and similar tracking technologies (web beacons, pixels, local storage, session storage) to collect information, enhance functionality, and improve your experience on the Platform. For non-essential cookies (including analytics and marketing cookies), we will obtain your consent before placing these cookies on your device. You can manage your cookie preferences at any time through your browser settings or through your Account settings on the Platform.

8.2 Types of Cookies We Use

(a) Essential Cookies (strictly necessary):

– Authentication and session management;

– Security and fraud prevention;

– Load balancing and Platform stability;

– Remembering your login state; and

– These cookies are necessary for the Platform to function and cannot be disabled in our systems.

(b) Functional Cookies:

– Remembering your preferences and settings;

– Maintaining language preferences;

– Customising User interface elements; and

– Improving usability.

– Understanding how Users interact with the Platform;

– Measuring page views, navigation paths, and session duration;

– Identifying technical issues and errors;

– Improving Platform performance; and

– We may use services such as Google Analytics or similar tools for this purpose. We will obtain your consent before placing these analytics cookies on your device, which you can manage through your browser settings or your Account settings.

(d) Marketing and Advertising Cookies (consent required):

– Measuring the effectiveness of marketing campaigns;

– Providing relevant content and advertisements; and

– Retargeting and remarketing.

8.3 Third-Party Cookies

Third-party service providers (e.g., analytics providers, advertising networks) may set cookies when you use the Platform. We will obtain your prior informed consent before allowing third parties to place non-essential cookies on your device, in accordance with the Privacy Act and applicable electronic marketing laws. These third-party cookies are subject to the privacy policies of those third parties. While we do not control their use of cookies, we take reasonable steps to ensure that third-party service providers comply with Australian privacy law standards when handling your Personal Information.

8.4 Managing Cookies

You can control and manage cookies through your browser settings:

(a) Browser Settings: Most browsers allow you to:

– View and delete cookies;

– Block third-party cookies;

– Block all cookies (though this may affect Platform functionality); and

– Receive notifications when cookies are set.

(b) Platform Settings: You can manage certain cookie preferences through your Account settings on the Platform.

– Google Analytics Opt-Out: https://tools.google.com/dlpage/gaoptout

– Network Advertising Initiative: http://www.networkadvertising.org/choices/

– Digital Advertising Alliance: http://www.aboutads.info/choices/

8.5 Do Not Track (DNT)

Some browsers transmit "Do Not Track" (DNT) signals. Currently, there is no industry consensus on how to respond to DNT signals. As such, we do not currently respond to DNT browser settings or signals.

9. CHILDREN'S PRIVACY

9.1 Age Restrictions

The Platform is intended for use by individuals who are at least 18 years of age. Individuals who are 16 or 17 years of age may use the Platform only with verifiable parental or guardian consent obtained in accordance with the requirements set out below in this Section 9.

We do not knowingly collect Personal Information from children under 16 years of age without verifiable parental or guardian consent.

9.2 Parental Consent

If you are under 16 years of age, you must not:

(a) Create an Account;

(b) Use the Platform; or

without verifiable parental or guardian consent. We implement reasonable age verification mechanisms and parental consent verification processes designed to prevent underage users from accessing the Platform without proper authorisation. However, we cannot guarantee that all underage access will be prevented.

If you are 16 or 17 years of age, you must obtain verifiable consent from your parent or guardian before creating an Account, and we strongly encourage you to review this Privacy Policy with them.

9.3 Deletion of Children's Information

If we become aware that we have inadvertently collected Personal Information from a child under 16 without proper parental consent, we will take steps to delete that information as soon as reasonably practicable.

If you are a parent or guardian and believe we have collected information from your child without consent, please contact us immediately at [email protected] so we can investigate and, if appropriate, delete the information.

9.4 Special Protections for Minors

For Users between 16 and 18 years of age, we take additional care to:

(a) Ensure age-appropriate content moderation;

(b) Provide additional safety features and privacy controls where appropriate; and

10. THIRD-PARTY LINKS AND SERVICES

10.1 Third-Party Websites and Services

The Platform may contain links to third-party websites, applications, or services that are not owned, operated, or controlled by Strybe, including:

(a) Social media platforms (e.g., Instagram, TikTok, Facebook, X, YouTube);

(b) Payment processors (including Stripe, Apple, and other payment service providers);

(d) Third-party tools or services integrated with the Platform.

10.2 Third-Party Privacy Practices

We are not responsible for the privacy practices, content, security, or policies of third-party websites or services. These third parties have their own privacy policies, and we encourage you to read them before providing any Personal Information or using their services.

The inclusion of links to third-party sites does not imply endorsement by Strybe.

10.3 Social Media Features

The Platform may include social media features (e.g., sharing buttons, embedded feeds, widgets) that are hosted and operated by third parties. Your interactions with these features, including any information you provide, are governed by the privacy policies of the companies providing them.

11. INTERNATIONAL DATA TRANSFERS

11.1 Data Storage Location

Your Personal Information is primarily stored on servers located in Australia. However, some of our third-party service providers may store or process data in other countries, including the United States and other jurisdictions.

If you access the Platform from outside Australia, you acknowledge that your Personal Information is transferred to, and processed in, Australia, and that it is handled in accordance with Australian law and this Privacy Policy. Where the privacy law of your country confers additional rights on you, we will honour those rights to the extent they apply to us. Users in the United Kingdom or European Economic Area may contact us at [email protected] to exercise any right of access, rectification, erasure, restriction, portability, or objection conferred by the UK GDPR or the EU GDPR.

11.2 Cross-Border Disclosure

In accordance with Australian Privacy Principle 8 (Cross-border Disclosure of Personal Information), when we disclose your Personal Information to overseas recipients, we take reasonable steps to ensure that one of the following applies:

(a) The overseas recipient does not breach the Australian Privacy Principles in relation to that information;

(b) You have consented to the disclosure after being expressly informed that APP 8 will not apply; or

11.3 Countries Where Data May Be Transferred

Personal Information may be transferred to, stored in, or processed in the following countries through our service providers:

(a) United States (cloud hosting providers, payment processors, analytics services);

(b) European Union member states, United Kingdom, Singapore, and other countries where our cloud hosting, content delivery, payment processing, analytics, or support service providers maintain data centres or processing facilities; and

11.4 Your Acknowledgment

By using the Platform, you acknowledge that your Personal Information may be transferred to the countries identified in clause 11.3 for the purposes described in this Privacy Policy. Where we rely on your consent for cross-border disclosure under APP 8.1(b), we will obtain your separate express consent after expressly informing you that:

(a) APP 8 will not apply to the disclosure;

(b) we will not be accountable under the Privacy Act for any acts or practices of the overseas recipient; and

(c) you will not be able to seek redress under the Privacy Act and may need to seek redress in the overseas jurisdiction, which may not provide the same level of protection as Australian privacy law.

11.5 Accountability

Where we disclose Personal Information to overseas recipients, we:

(a) Where we rely on APP 8.1(a), enter into binding contracts requiring overseas recipients to handle Personal Information in accordance with the Australian Privacy Principles, and take reasonable steps to enforce those contractual provisions;

(b) Conduct due diligence on overseas recipients to assess their privacy and security practices;

(d) Remain accountable under the Privacy Act for any acts or practices of the overseas recipient in relation to your Personal Information that would breach the Australian Privacy Principles, except where we have obtained your consent under APP 8.1(b) or another exception under APP 8.1 or 8.2 applies.

12. AUSTRALIAN PRIVACY PRINCIPLES COMPLIANCE

Strybe is committed to complying with the Australian Privacy Principles (APPs) under the Privacy Act.

12.1 APP Compliance Summary

We handle Personal Information in accordance with all 13 Australian Privacy Principles:

APP 1 - Open and transparent management of Personal Information: This Privacy Policy provides clear information about how we manage Personal Information.

APP 2 - Anonymity and pseudonymity: Where practicable and lawful, you may interact with us anonymously or using a pseudonym (e.g., username instead of real name for certain public interactions). However, for services including account registration, payment processing, identity verification, and compliance with legal obligations (including anti-money laundering and counter-terrorism financing laws), we are required by law or it is impracticable for us to deal with you if you do not identify yourself.

APP 3 - Collection of solicited Personal Information: We only collect Personal Information that is reasonably necessary for our functions and activities as described in this Privacy Policy.

APP 4 - Dealing with unsolicited Personal Information: If we receive unsolicited Personal Information, we will within a reasonable period determine whether we could have collected it under APP 3. If not, and it is lawful and reasonable to do so, we will destroy or de-identify it as soon as practicable. If we are required by law to retain the information, we will ensure it is protected in accordance with the APPs.

APP 5 - Notification of collection: We notify you about the collection of Personal Information through this Privacy Policy and at the point of collection.

APP 6 - Use or disclosure of Personal Information: We only use and disclose Personal Information for the purposes for which it was collected, as described in Section 3 of this Privacy Policy, or for secondary purposes where you would reasonably expect such use or where permitted by law.

APP 7 - Direct marketing: We only use or disclose Personal Information for direct marketing purposes in accordance with APP 7 and the Spam Act 2003 (Cth). This includes: (i) only using or disclosing personal information for direct marketing where you would reasonably expect such use or where we have obtained your consent; (ii) providing a simple and free means to opt out of direct marketing in each communication; (iii) not using or disclosing sensitive information for direct marketing unless you have consented; (iv) not using or disclosing personal information collected from third parties for direct marketing unless you have consented or it is impracticable to obtain consent; and (v) honouring opt-out requests within a reasonable period (no more than 30 days).

APP 8 - Cross-border disclosure: We comply with APP 8 when disclosing Personal Information to overseas recipients, as described in Section 11 of this Privacy Policy.

APP 9 - Adoption, use, or disclosure of government-related identifiers: We do not adopt government identifiers (such as driver's licence numbers, Medicare numbers, or passport numbers) as our own identifiers for individuals. We may collect, use, or disclose government identifiers only where: (i) the use or disclosure is required or authorised by or under an Australian law or a court/tribunal order; or (ii) reasonably necessary for us to verify your identity for the purposes of our activities or functions; or (iii) reasonably necessary for us to fulfil our obligations to an agency or State or Territory authority; or (iv) a permitted general situation exists in relation to the use or disclosure.

APP 10 - Quality of Personal Information: We take reasonable steps to ensure that Personal Information we collect, use, or disclose is accurate, up-to-date, complete, relevant, and not misleading.

APP 11 - Security of Personal Information: We implement appropriate security measures to protect Personal Information as described in Section 6 of this Privacy Policy.

APP 12 - Access to Personal Information: We provide access to Personal Information in accordance with your rights as described in Section 7.1 of this Privacy Policy. If we refuse to provide access, we will provide you with written reasons for the refusal (unless one of the exceptions under APP 12.3 applies or it would be unreasonable to do so) and inform you of the mechanisms available to complain about the refusal.

APP 13 - Correction of Personal Information: We will take reasonable steps to correct Personal Information upon request in accordance with Section 7.2 of this Privacy Policy. If we refuse to correct Personal Information, we will provide you with written reasons for the refusal (except to the extent it would be unreasonable to do so) and inform you of the mechanisms available to complain about the refusal, including your right to make a complaint to the Office of the Australian Information Commissioner. If you request that we associate a statement with your Personal Information that you believe it to be inaccurate, out-of-date, incomplete, irrelevant or misleading, we will take reasonable steps to do so and will not charge you for making the request, associating the statement with your personal information, or for providing you with details of any correction made or statement associated.

13. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect:

(a) Changes in our privacy practices or operations;

(b) Changes to applicable privacy laws and regulations;

(d) Changes to our service providers or business relationships.

13.1 Notification of Changes

We will notify you of material changes to this Privacy Policy by:

(a) Updating the "Last Updated" date at the top of this Privacy Policy;

(b) Posting a prominent notice on the Platform;

(d) Displaying an in-app notification when you next log in.

13.2 Your Acceptance

We will seek your consent where required by law before applying material changes to this Privacy Policy. Your continued use of the Platform following notification of changes may constitute your acceptance of the revised Privacy Policy, subject to any legal requirements for express consent. If you do not agree to the revised Privacy Policy, you should stop using the Platform and may delete your Account.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your Personal Information.

14. CONTACT INFORMATION

If you have any questions, concerns, requests, or complaints regarding this Privacy Policy or our privacy practices, please contact us:

SPORTS EXCLUSIVE PTY LTD ACN 684 430 895 trading as Strybe

Privacy Officer Email: [email protected]

Postal Address: c/- Dib & Associates Accountants, Nexus Towers, Suite 17, 105 Scarborough Street, Southport QLD 4215, Australia

We will acknowledge receipt of your inquiry and respond within a reasonable timeframe.