PRIVACY POLICY

SportyTok Ltd. ("SportyTok," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our mobile application (collectively, the "Platform").

We value your trust and strive to be transparent about our data practices. Please read this Privacy Policy carefully. By accessing or using the Platform, you acknowledge that you have read, understood, and agree to be bound by all the terms of this Privacy Policy and our Terms of Service.

If you do not agree with the terms of this Privacy Policy, please do not access the Platform. We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the "Last Updated" date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates.

We collect information that you voluntarily provide to us when you register on the Platform, express an interest in obtaining information about us or our products and services, participate in activities on the Platform, or otherwise contact us. The personal information we collect depends on the context of your interactions with us and the Platform, the choices you make, and the products and features you use.

1.1 Personal Information

The personal information we collect may include the following:

• Account Information: When you create an account, we collect your name, email address, date of birth, country of residence, and password.
• Profile Information: You may choose to provide additional information for your profile, such as a profile picture, interests, and preferences.
• Payment Information: If you make withdrawals from the Platform, we collect payment information necessary to process your request, such as your payment method details and billing address. All payment information is stored by our payment processors, and you are encouraged to review their privacy policies and contact them directly with any questions.
• Communications: If you contact us directly, we may receive additional information about you, such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.
• Testimonials: If you provide us with testimonials or reviews, we may publish these along with your name and other information you have provided to us.

1.2 Automatically Collected Information

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

• Device Information: We collect information about the device you use to access the Platform, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
• Log Information: We collect log information when you use our Platform, including access times, pages viewed, IP address, browser type, and the page you visited before navigating to our Platform.
• Usage Information: We collect information about your interactions with the Platform, such as the ads you view, the time spent on various pages, the links you click, and your search queries.
• Location Information: We may collect information about your approximate location based on your IP address.
• Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to collect information about your interactions with our Platform. For more information, please see our Cookie Policy.

1.3 Information from Third Parties

We may receive information about you from third parties, including:

• Social Media Platforms: If you choose to link your social media account to our Platform, we may receive information about you from the social media platform, such as your profile information, friends list, and other information you have made public on the platform.
• Analytics Providers: We work with third-party analytics providers to collect and analyze information about your use of the Platform.
• Advertising Partners: We work with third-party advertising partners to display ads to you on our Platform and on other websites and services. These advertising partners may use cookies and similar technologies to collect information about your interactions with our Platform and other websites.
• Referrals: If you are referred to our Platform by another user, we may receive information about you from that user.

We use the information we collect for various purposes, including to:

2.1 Provide, Maintain, and Improve the Platform

• Create and manage your account
• Process your transactions and send you related information
• Provide the services you request
• Respond to your comments, questions, and requests
• Develop new products and services
• Improve the functionality and user experience of our Platform
• Monitor and analyze trends, usage, and activities in connection with our Platform

2.2 Personalize Your Experience

• Customize the content and advertisements you see
• Provide personalized rewards and offers
• Recommend features, products, and services that might be of interest to you
• Tailor the advertisements you see to your interests and preferences

2.3 Communicate with You

• Send you technical notices, updates, security alerts, and support and administrative messages
• Communicate with you about products, services, offers, promotions, and events
• Provide news and information we think will be of interest to you
• Respond to your inquiries and provide customer support

2.4 Ensure Security and Prevent Fraud

• Detect, investigate, and prevent fraudulent transactions and other illegal activities
• Protect the rights, property, and safety of our users and others
• Enforce our Terms of Service and other policies
• Verify your identity and prevent multiple accounts

2.5 Legal Compliance

• Comply with applicable laws, regulations, and legal processes
• Respond to lawful requests for information from governmental authorities
• Establish, exercise, or defend legal claims

We may combine information we collect about you from various sources to improve our Platform and the services we provide to you.

We may share your information in the following circumstances:

3.1 With Service Providers

We may share your information with third-party service providers who perform services on our behalf, such as:

• Payment processors to process transactions
• Cloud storage providers to store our data
• Analytics providers to help us understand how users interact with our Platform
• Email service providers to send communications
• Customer service providers to assist with user inquiries
• Fraud prevention services to protect against unauthorized activities

These service providers are contractually obligated to use your information only as necessary to provide services to us and in accordance with this Privacy Policy.

3.2 With Advertising Partners

We work with third-party advertising companies to display ads on our Platform and on other websites and services. These companies may use cookies, web beacons, and similar technologies to collect information about your interactions with our Platform and other websites to provide you with more relevant advertisements.

We share limited, anonymized data with advertisers to improve ad targeting and effectiveness:

• Demographic information (age range, country, general interests)
• Engagement metrics (completion rates, click-through rates)
• Performance statistics

We do not share your name, email address, exact location, or payment information with advertisers.

3.3 For Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of our assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.

3.4 For Legal Reasons

We may disclose your information if we believe in good faith that such disclosure is necessary to:

• Comply with relevant laws, regulations, legal processes, or governmental requests
• Enforce our Terms of Service and other agreements, including investigation of potential violations
• Detect, prevent, or address fraud, security, or technical issues
• Protect against harm to the rights, property, or safety of SportyTok, our users, or the public as required or permitted by law

3.5 With Your Consent

We may share your information with third parties when you have given us your consent to do so.

3.6 Aggregated or De-identified Information

We may share aggregated or de-identified information, which cannot reasonably be used to identify you, with third parties for research, marketing, analytics, and other purposes.

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide services to you
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time)
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations)

When we no longer need to use your personal information, we will either delete it from our systems or anonymize it so that it can no longer be associated with you. However, some information may be retained in backup copies for a limited period or as required by law.

4.1 Account Deletion

You may delete your account at any time through the account settings page. Upon deletion, your account and all associated data will be permanently removed from our systems after a 30-day grace period. During this period, your account will be deactivated but not deleted, allowing you to reactivate it if you change your mind.

4.2 Dormant Accounts

If your account is inactive for more than 6 months, it may be classified as dormant. We may send you a notification before taking any action on dormant accounts. If you do not respond to our notification, we may deactivate your account and archive your data in accordance with our data retention policies.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. These measures include:

• Encryption: We use industry-standard encryption to protect your data in transit and at rest.
• Access Controls: We restrict access to personal information to authorized employees, contractors, and service providers who need to know that information in order to operate, develop, or improve our Platform.
• Regular Audits: We conduct regular security assessments and penetration testing to identify and address potential vulnerabilities.
• Secure Infrastructure: Our systems are hosted on secure cloud platforms with industry-standard protections.
• Employee Training: We train our employees on privacy and security best practices.
• Incident Response: We have procedures in place to respond to potential data breaches.

However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. In the event of a data breach that affects your personal information, we will notify you in accordance with applicable laws.

5.1 Your Role in Security

You also play a role in protecting your information. Please:

• Keep your account password confidential and use a unique password
• Enable two-factor authentication if available
• Log out of your account when using shared devices
• Notify us immediately if you suspect any unauthorized access to your account
• Be cautious about sharing personal information in public areas of the Platform

We use cookies, web beacons, pixels, and similar tracking technologies to collect information about your browsing activities on our Platform and to allow the Platform to recognize your device during subsequent visits.

6.1 Types of Cookies We Use

• Essential Cookies: These cookies are necessary for the Platform to function properly and cannot be switched off in our systems. They are usually set in response to actions made by you, such as setting your privacy preferences, logging in, or filling in forms.
• Analytical/Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Platform. They help us know which pages are the most and least popular and see how visitors move around the Platform.
• Functionality Cookies: These cookies enable the Platform to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages.
• Targeting Cookies: These cookies may be set through our Platform by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites.

6.2 Managing Cookies

Most web browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may worsen your overall user experience and/or lose access to certain features of our Platform.

For more detailed information about cookies and how we use them, please visit our Cookie Policy.

6.3 Do Not Track

Some browsers have a "Do Not Track" feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser "Do Not Track" signals, but we do provide you the option to opt out of interest-based advertising. To learn more about interest-based advertising or to opt-out of this type of advertising by participating ad networks, please visit http://www.aboutads.info/choices.

Depending on your location, you may have certain rights regarding your personal information. These may include:

7.1 Access and Portability

You have the right to request a copy of the personal information we hold about you. You may also have the right to receive this information in a structured, commonly used, and machine-readable format.

7.2 Correction

You have the right to request that we correct any inaccurate or incomplete personal information we hold about you.

7.3 Deletion

You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected.

7.4 Restriction of Processing

You have the right to request that we restrict the processing of your personal information in certain circumstances, such as when you contest the accuracy of the data.

7.5 Objection

You have the right to object to the processing of your personal information in certain circumstances, such as when the processing is based on our legitimate interests.

7.6 Withdrawal of Consent

Where we rely on your consent to process your personal information, you have the right to withdraw your consent at any time.

7.7 Complaint

You have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal information violates applicable law.

To exercise any of these rights, please contact us using the information provided in the "Contact Us" section below. We will respond to your request within the timeframe required by applicable law.

Please note that we may need to verify your identity before processing your request. In some cases, we may need to keep certain information for recordkeeping purposes, to complete transactions, or to comply with our legal obligations.

SportyTok is based in the United Kingdom, and we process and store information on servers located in the United Kingdom and other countries. If you are located outside the United Kingdom, please be aware that information we collect, including personal information, may be transferred to, processed, and stored in countries where the data protection laws may differ from those of your country.

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we comply with applicable data protection laws when transferring your personal information outside of these areas. We may transfer your personal information to countries that have been deemed to provide an adequate level of protection, use specific contracts approved for use in the UK and EU which give personal data the same protection it has in the UK and EU, or use providers who are certified under the EU-US Data Privacy Framework and UK Extension.

8.1 Legal Basis for Processing (EEA, UK, and Switzerland)

If you are located in the EEA, UK, or Switzerland, we will only process your personal information when we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost all cases, the legal basis will be one of the following:

• Consent: You have consented to the processing of your personal information for one or more specific purposes.
• Performance of a Contract: Processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract.
• Legal Obligation: Processing is necessary for compliance with a legal obligation to which we are subject.
• Legitimate Interests: Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms.

If you have questions about the legal basis for processing your personal information, please contact us using the information provided in the "Contact Us" section below.

Our Platform is not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and you believe that your child has provided us with personal information, please contact us using the information provided in the "Contact Us" section below. If we become aware that we have collected personal information from children without verification of parental consent, we will take steps to remove that information from our servers.

Our Platform may contain links to third-party websites, services, or applications that are not operated by us. When you click on a link to a third-party website, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. The inclusion of links to such sites does not imply an endorsement or recommendation.

10.1 Social Media Features

Our Platform may include social media features, such as the Facebook Like button or Twitter sharing button. These features may collect your IP address, which page you are visiting on our Platform, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Platform. Your interactions with these features are governed by the privacy policy of the company providing them.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Last Updated" date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify you either through the email address you have provided us or by placing a prominent notice on our Platform. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

Your continued use of our Platform after the effective date of the revised Privacy Policy constitutes your acceptance of the revised Privacy Policy.

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us:

For data subjects in the EU, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

By using our Platform, you acknowledge that you have read and understand this Privacy Policy. If you do not agree with our policies and practices, please do not use our Platform.