AXIORA

AXIORA PRIVACY POLICY — Sentinel Black Unit, Inc.

Reproduction of Section 2 of the Master Agreement in force as of September 2026. It does not constitute an independent legal document.

SECTION 2: PRIVACY POLICY · English Version · Last updated: SEPTEMBER 2026

This Privacy Policy describes how AXIORA ("AXIORA", "we", "our" or the "Application") collects, uses, stores, protects and shares information related to Users of the Application.

INFORMATION WE COLLECT

1.1 Information provided directly by the User

a) Registration information: Mobile phone number. Language preferences. Notification settings. Information necessary for the creation and administration of the account. Use of the device's biometric authentication mechanisms, when the User chooses to use features such as Face ID, Touch ID, fingerprint or other compatible biometric mechanisms to access or authenticate in the Application. AXIORA does not collect, store or receive the facial images, fingerprints or other biometric data used by the device's operating system. Biometric authentication is processed locally by the device and AXIORA receives only the authentication result necessary to allow or deny the corresponding access.

b) Subscription-related information: Type of plan selected. Subscription status. Billing information administered by authorized external providers. AXIORA does not store complete credit or debit card numbers.

c) Usage information: Games consulted. Tools used. Combinations generated. Analyses viewed. Usage preferences within the Application.

d) Ticket images: When the User voluntarily uses the ticket scanning feature, AXIORA may access the device's camera or images selected by the User, as applicable, to capture or provide an image of the ticket. The image will be processed through automated image processing and artificial intelligence service providers, exclusively for the purpose of extracting the numbers and other necessary data from the ticket. AXIORA does not permanently store the captured images nor use them for purposes other than providing this functionality.

1.2 Information collected automatically

a) Device data: Device type. Operating system. Technical device identifiers. Performance and diagnostic information.

b) Usage data: Access frequency. Usage duration. Features used. Error and technical event logs.

c) IP address and technical connection data: IP address associated with the use of the Application, when necessary for security purposes, prevention of fraud, abuse or protection of our services. The IP address is not used to determine the User's location, for advertising, or for the creation of advertising profiles. The IP address is retained for a maximum of ninety (90) days and is automatically deleted once that period has elapsed.

AXIORA does not collect or store precise or approximate User location data through GPS, IP address or other geolocation mechanisms.

HOW WE USE YOUR INFORMATION

2.1 We use the information collected to:

a) Provide and operate the Application: Verify identity via SMS. Administer user accounts. Manage subscriptions. Provide technical support. Enable authentication through the biometric mechanisms available on the User's device, when the User has chosen to use them.

b) Improve our services: Analyze usage patterns. Detect errors. Optimize existing functionality. Develop new features.

c) Communications: Send verification codes. Security alerts. Account-related notifications. Legal and contractual notices. AXIORA will not send promotional or marketing communications without the corresponding consent when required by applicable law.

d) Legal compliance and security: Comply with legal obligations. Protect our rights. Prevent fraud, abuse or misuse. Investigate security incidents.

HOW WE SHARE YOUR INFORMATION

3.1 AXIORA does not sell its Users' personal information.

3.2 We may share information with:

a) Service providers: Authentication and SMS services. Apple App Store and Google Play, in connection with the management of purchases, subscriptions and payments made through their respective platforms. Hosting and infrastructure services. Analytics and monitoring tools. Technical support providers.

b) Authorities and legal obligations: When required by law. To respond to valid court orders or governmental requests. To protect the rights, safety or property of AXIORA, its Users or third parties.

c) Image processing providers: technology providers that temporarily process ticket images submitted by the User to perform automated recognition and information extraction functions.

3.3 AXIORA may use aggregated, anonymized or de-identified information for statistical, analytical or service improvement purposes.

INFORMATION SECURITY

4.1 AXIORA implements reasonable administrative, technical and organizational measures to protect personal information against loss, unauthorized access, alteration, disclosure or destruction.

4.2 Such measures include: Encryption of data in transit using TLS/SSL. Encryption of sensitive information at rest. Restricted access controls. Security monitoring. Internal incident management procedures.

4.3 No electronic transmission or storage system can guarantee absolute security.

DATA RETENTION

5.1 We will retain information only for as long as reasonably necessary to: Operate the User's account. Comply with legal obligations. Resolve disputes. Enforce our agreements.

5.2 In general: Active account: for as long as it remains in force. SMS codes: until their expiration or use. IP addresses: up to 90 days. Payment-related information: according to applicable tax and regulatory obligations.

5.3 Account and data deletion request: The User may request the deletion of their account and associated personal data through the deletion mechanisms available within the Application or through the external resource designated by AXIORA. When the deletion of an account is requested, AXIORA will delete the personal data associated with such account that is no longer necessary for the provision of the Service, except for data that must be legitimately retained to comply with legal, tax or regulatory obligations, resolve disputes, prevent fraud or abuse, enforce these Terms, or protect the rights and safety of AXIORA, its Users or third parties. The deactivation, suspension or blocking of an account does not constitute an account deletion. Any information that must be retained for one of the reasons indicated above will be retained only for the period necessary to fulfill such purpose. The designated external account deletion resource is available at: https://privacy.axiora.email/delete-account.

PRIVACY RIGHTS

6.1 Depending on the applicable jurisdiction, the User may have the right to: Access their personal information. Correct inaccurate information. Request deletion of data. Obtain a copy of certain data. Object to certain processing. Request limitation of processing.

6.2 Requests may be sent to: privacy@axiora.email

6.3 AXIORA will respond within the time frames required by applicable law.

6.4 PURCHASES, BILLING AND PAYMENT PROCESSING

Subscriptions and other purchases offered through AXIORA are acquired through the third-party purchase and billing systems provided by the Apple App Store and Google Play, as applicable to the device and platform used by the User. Payment processing, transaction authorization, issuance of the purchase receipt, management of the payment method and certain aspects related to the billing of the transaction are handled by Apple or Google, as applicable, in accordance with their respective terms, policies and procedures.

AXIORA does not receive or store the complete credit or debit card numbers used for such purchases. AXIORA also does not receive access to the complete payment method data used by the User through the Apple App Store or Google Play. AXIORA receives only the transaction information that such platforms make available to the developer and that is necessary to verify, administer or provide the purchased functionality.

AXIORA may receive from Apple or Google transaction-related information that is necessary to verify the purchase, administer the subscription, enable or maintain access to the corresponding functionality, handle support inquiries and comply with legal or regulatory obligations.

Inquiries related to the operation of AXIORA, access to purchased functionality, recognition of a subscription, errors in the provision of the service or problems with a purchase may be directed to support@axiora.email. When an inquiry specifically concerns payment processing, billing, cancellation or refunds handled by the Apple App Store or Google Play, AXIORA may direct the User to the corresponding support mechanism of the platform used. Refund requests will be subject to the applicable policies of Apple, Google, AXIORA and applicable law, as appropriate.

RIGHTS OF UNITED STATES RESIDENTS

7.1 Residents of certain states of the United States may have additional privacy rights under applicable law.

7.2 California residents may have specific rights under the California Consumer Privacy Act (CCPA) and its subsequent amendments.

7.3 AXIORA does not sell Users' personal information.

STORAGE AND SESSION TECHNOLOGIES

8.1 AXIORA may use: Local storage. Authentication tokens. Usage analytics tools. Technologies necessary for the operation of the Application.

8.2 AXIORA does not use technologies intended to sell personal information or third-party advertising profiles.

MINORS

9.1 AXIORA is not directed at persons under eighteen (18) years of age.

9.2 We do not knowingly collect personal information from minors.

9.3 If we detect that information from a minor has been collected, we will take reasonable steps to delete it.

DATA TRANSFERS AND PROCESSING

10.1 Information may be processed or stored in the United States or in other countries where our technology providers operate.

10.2 By using the Application, the User acknowledges and accepts such transfers when necessary for the provision of the services.

10.3 Territorial availability: The Application and the Service are marketed, distributed and offered exclusively in the United States of America. AXIORA does not direct its services to users located in other jurisdictions.

CHANGES TO THIS POLICY

11.1 AXIORA may modify this Privacy Policy from time to time.

11.2 Significant changes may be notified through the Application, email or any other reasonable means.

11.3 The last updated date will indicate the version in force.

CONTACT

For inquiries related to privacy or data protection: Email: privacy@axiora.email

AXIORA will handle requests within the time frames established by applicable law.

privacy@axiora.email