Privacy Policy

Beat The Odds LLC ("BTO," "we," "us," or "our") is a Texas limited liability company. This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you use our mobile applications, websites, and related services (collectively, the "Platform").

The Platform is a paid-entry fantasy sports contest service restricted to adults 21 and older in eligible U.S. states. Because of that, we collect identity and location information that a general-audience app would not. This policy describes what we collect and why.

By accessing or using the Platform, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the Platform.

1. Information We Collect

Account Data

When you create an account in the Beat The Odds app, we collect your first and last name, email address, password, date of birth, and your state of residence. You may also enter a referral code. We do not ask for a phone number during signup in the iOS app; if you give us one through another channel, we store it with your account.

Venue and kiosk operators additionally provide a venue/business name, business address, and operator contact information as part of venue onboarding.

Identity Verification Data

Fantasy sports contests are regulated, so before you can enter contests for value we may ask you to verify your identity. That verification collects your legal name, date of birth, the last four digits of your Social Security number, and your street address (street, city, state, and ZIP code). We use this information to confirm that you are who you say you are, that you meet the minimum age, and that you are eligible to play — not for marketing.

Precise Location Data

When you verify your eligibility to play, the app asks your permission to access your device location and then reads your precise location (latitude and longitude). We transmit those coordinates to our compliance service and resolve them to a state so we can confirm you are physically located somewhere we are permitted to offer contests. We request location only while you are using the app; we do not track your location in the background.

You can decline this permission, or revoke it later in your device settings. If you do, we cannot verify your eligibility and contest entry will be unavailable to you.

The Beat The Odds kiosk app used by venue staff does not collect location.

Device Data

We collect device identifiers (e.g., device model, operating system version) and push notification tokens so we can deliver notifications you have opted into.

Wallet and Transaction Data

We record your contest entries, your results, and your wallet balances. The app includes deposit and withdrawal features. When those features are enabled for your account, we and our payment provider process the information needed to move money — the payment method you choose and the amount, date, and status of each transaction.

Real-money deposits and withdrawals are currently switched off across the Platform while we complete payment-provider onboarding, and balances operate in play-money mode during that period. These features are part of the app and can be enabled without a new app release, so this policy describes them now.

Diagnostic Data

We use a crash-reporting and performance-monitoring service (Sentry) to find and fix errors. Crash reports and performance traces are tagged with your account's internal user identifier so we can trace a specific failure. In the Beat The Odds bettor app, that identifier is the only account information sent — your email address is not. In the kiosk app used by venue staff, the user identifier, email address, and venue identifier are sent. Authorization headers, tokens, passwords, and secrets are redacted before a report leaves the device.

What We Do Not Collect

We do not run a product-analytics pipeline: the apps do not transmit usage or product-interaction analytics to us or to any analytics vendor. We do not collect your contacts, photos, microphone audio, health data, browsing history, or search history. We do not use advertising identifiers (IDFA), ad networks, attribution SDKs, or any form of cross-app or cross-site tracking, and we do not share your data with data brokers.

2. How We Use Your Information

We use the information we collect to:

• Create and manage your account
• Verify your age, identity, and physical location so we can confirm you are eligible to enter contests
• Operate contests and maintain your wallet balances and contest history
• Process deposits, withdrawals, and other transactions when those features are enabled
• Deliver push notifications you have opted into
• Diagnose crashes, errors, and performance problems
• Detect and prevent fraud, abuse, and security incidents
• Communicate service updates and promotional information
• Comply with legal, regulatory, and record-keeping obligations

3. Third-Party Services

We use the following categories of third-party service providers:

• Authentication: AWS Cognito for secure account authentication
• Push Notifications: Apple Push Notification service (APNs) and Firebase Cloud Messaging (FCM)
• Crash & Performance Monitoring: Sentry, which receives crash reports and performance traces tagged with your internal user identifier as described in Section 1
• Hosting & Infrastructure: Amazon Web Services (AWS)
• Payments & Identity Verification: When deposits, withdrawals, and identity verification are enabled, a payment processor and an identity-verification provider receive only the information needed to complete those specific tasks. [COUNSEL: name the payment processor and the identity-verification vendor here once those agreements are executed. Neither is live today, so no vendor is named.]

These providers only receive the data necessary to perform their services and are contractually obligated to protect your information. We do not use analytics or advertising vendors.

4. Data Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

• Service Providers: With third-party vendors who help us operate the Platform, subject to confidentiality obligations
• Legal Requirements: When required by law, regulation, legal process, or governmental request
• Regulators: With state gaming or consumer-protection regulators where we are required to report on eligibility, identity verification, or transactions
• Safety & Security: To protect the rights, property, or safety of BTO, our users, or the public
• Business Transfers: In connection with a merger, acquisition, or sale of assets, with notice to you

5. Data Retention

We retain your personal information for as long as your account is active or as needed to provide you services. If you request deletion of your account, we will delete or anonymize your personal data within 30 days, except where retention is required by law.

Identity-verification records and transaction records are subject to regulatory record-keeping rules and are retained on a separate schedule from the rest of your account data. [COUNSEL: state the specific retention period for identity-verification (KYC) and transaction records required by the applicable state fantasy-sports and anti-money-laundering rules. Engineering cannot set this number.]

6. Your Rights

Depending on your location, you may have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate information
• Request deletion of your personal information
• Request a portable copy of your data
• Opt out of promotional communications

To exercise any of these rights, contact us at support@btofantasy.us. We will respond within 30 days. Deleting your account does not delete records we are required to keep under Section 5.

7. Age Restriction and Children's Privacy

You must be at least 21 years old to create an account. We enforce this on our servers using the date of birth you provide, and we may require additional proof of age. The Platform is not directed to minors.

The Platform is not intended for children under the age of 13, and we do not knowingly collect personal information from children under 13 in compliance with COPPA. If we learn that we have collected information from a child under 13, we will delete that information promptly. If we learn that an account holder is under 21, we will close the account.

8. Security

We implement industry-standard security measures to protect your personal information, including encryption in transit and at rest, secure authentication protocols, and regular security assessments. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

9. Cookies and Tracking Technologies

Our web properties use essential cookies required for authentication and session management. We do not use third-party advertising cookies. For more details on the cookies we use and how to manage your preferences, visit our Privacy Preferences page.

10. California Residents (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to Know: You may request the categories and specific pieces of personal information we have collected about you
• Right to Delete: You may request deletion of your personal information, subject to certain exceptions
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights
• No Sale of Personal Information: We do not sell personal information as defined by the CCPA

To submit a CCPA request, email us at support@btofantasy.us with the subject line "CCPA Request."

11. Changes to This Policy

We may update this Privacy Policy from time to time. For material changes, we will notify you via the Platform or by email. The "Effective Date" at the top of this page indicates when the policy was last revised. Your continued use of the Platform after any changes constitutes acceptance of the updated policy.

12. Contact Us

If you have questions or concerns about this Privacy Policy, please contact us at: