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Privacy Policy

Last updated on August, __ 2026

FanThrill LLC (“FanThrill” “Company,” “us,” or “our”) appreciates your interest in our website (the “Site”). FanThrill is a free-to-play, non-wagering sports engagement platform. Users make predictions on live sports broadcasts, earn points ("Thrill Points"), and use those points to enter sweepstakes for prizes. The platform is built as a Progressive Web App (“PWA”) — no app store download required. Users may access it through their mobile browser. As part of our commitment to honoring your privacy, this Privacy Policy explains the approach we take in protecting and using the information that we gather from you or about you on the Site, through our PWA, and through our business operations as well as other services we may offer from time to time (“Services”).

By using our Site or Services, you agree to have your personal data collected, transferred, processed and stored in the United States, and to allow us to use such data pursuant to the terms of this Privacy Policy. While our website operations do not prohibit the collection of personal data from individuals located outside of the US, our business operations are directed to US residents and subject to the data privacy and protection laws of the US only, which may differ from the data privacy laws of the country where you reside.

If you do not agree with the terms of our Privacy Policy, or Terms of Use for this Site you should refrain from using the Site and not register for our Services.

How We Collect Information

The Privacy Policy applies to information we collect:

  • on the Site;
  • social media;
  • through mail, in e-mail and other electronic messages between you and the Site; or
  • through mobile and desktop applications, and forms you download from the Site;
  • through our PWA
  • through registration; and
  • with your consent through our surveys, contests, giveaways, or sweepstakes .

Types of Personal Information we Collect

We collect the following categories of personal information from users of our Site and Services:

  • Identifiers: Such as your name, email address, IP address, or other similar identifiers that may be linked to you, your devices, your Thrill Points and your digital wallet.
  • Internet Activity: Information related to your browsing history, search history, and interactions with our Service.
  • User Content: Any messages, comments, or other content that you submit, post, or otherwise transmit using our Service.
  • Geolocation Data: We may collect or process Information about your physical location by recording the US postal zip code at your location or residence.

Information You Provide

We collect information you provide directly when you create an account, enter a sweepstakes, add our digital card to your mobile wallet, contact us, or otherwise interact with our Services. This may include your display name, email address, avatar, mailing address (for sweepstakes winners), and date of birth (for age verification).

Prediction and Engagement Data

When you use our Services to make predictions on live sports broadcasts, we may analyze your interactions with our services, including engagement and viewing activity, to better understand audience interests, improve content delivery, measure performance, personalize user experiences, and support advertising and marketing activities. These analytics may include the creation of aggregated engagement metrics and predictive models designed to evaluate content performance and user interaction trends.

Guest/Anonymous User Data

We collect data before you create an account. Our Services allow you to play immediately as a guest without registering. When you use our Services as a guest, we collect the same prediction and engagement data described in Section 1.2, associated with a temporary anonymous profile. If you later create an account, we merge your anonymous guest profile — including all prediction history, engagement data, and earned Thrill Points — into your registered account.

3. Digital Wallet Card Data

We offer digital cards for Apple Wallet and Google Wallet that display your Thrill Points balance and member information. When you add our card to your wallet, we collect and store a profile identifier (“ProfileId”) that links your wallet card to your FanThrill account or guest profile. The wallet card enables session resumption — if your browser session is lost, the wallet card can restore your profile. We track when wallet cards are added to or removed from your device via webhook notifications from the wallet platform.

3.1 Device and Platform Data

We collect information about your device and viewing platform, including: device type, operating system, and browser type; IP address and general geographic location (we use IP-derived Designated Market Area, or DMA, to group users by broadcast region); the streaming platform you watch on (e.g., YouTube TV, ESPN+, Hulu Live, Fubo, DirecTV); and per-device latency calibration data used to synchronize predictions to your broadcast feed.

3.2 Information from Third Parties

We may receive information from third parties, including: live sports data providers (i.e., Sportradar, Genius Sports) who provide game event data we use to evaluate predictions; our wallet card platform provider (Passworks) who notifies us of card additions, updates, and removals; advertising partners who provide information about ad interactions; and [if applicable in the future] data enrichment partners who supplement our data with demographic and interest-based information.

4. How We Use Your Information

4.1 Service Delivery

We use your personal information to provide, maintain, and improve our Services, including: creating and managing your account (or anonymous guest profile); delivering prediction prompts synchronized to your live broadcast; calculating Thrill Points earned from predictions; processing your entry into sweepstakes and notifying winners; issuing and updating your digital wallet card; and calibrating your device's broadcast latency for split-second predictions.

4.2 Predictive Attention and Advertising

This is our primary commercial use of your data. We analyze your prediction and engagement data to compute your Predictive Attention Score (“PAS”) and to identify Anticipation Windows — the moments between when you commit to a prediction and when the outcome is revealed. We package these attention signals as premium advertising inventory and sell access to advertisers and sponsors. This means:

Advertisers can purchase ad placements targeted to users in verified high-attention states during Anticipation Windows.

We share aggregated and/or individual-level attention metrics (including PAS scores, engagement classifications, and timing data) with advertising partners to enable targeted ad delivery and to demonstrate the value of our advertising inventory.

Under California law, this sharing constitutes a "sale" and/or "sharing" of personal information. You have the right to opt out of these “sales” or “shares”. See Section 8 below.

4.3 Analytics and Improvement

We use your information for analytics and research to improve our Services, understand user behavior, develop new features, and enhance the accuracy of our prediction delivery and attention measurement systems.

5. How We Use Your Information

We use your personal information for the following purposes:

  • To operate, maintain, and improve, website and Services.
  • To allow you to participate in interactive features on the Site;
  • To register you for our Services;
  • To allow you to participate in competitions, surveys, sweepstakes, or contests you engage with us in;
  • To administer Thrill Points.
  • To send you information, status updates, notices, and other information related to the Service, including Thrill Point totals and account information.
  • To provide related customer service;
  • To provide you information about products and services from our sponsors and advertisers.
  • To send you special offers, information we believe is useful to our customers and prospective customers, where you have not opted out of receiving such information at the email address at which you are receiving it.
  • To notify you about changes to the Site or any Services we offer or provide though it;
  • Security: To protect the security and integrity of our Service and to prevent fraud or other malicious activity.
  • Legal Compliance: To comply with our legal obligations, enforce our terms of service, and address disputes we may need to provide your information to law enforcement agencies upon submission of a subpoena, or other lawful process. Depending on the nature of the request, we may not be able to advise you that law enforcement agencies are requesting such information.

At any time, you can request the removal or modification of your personally identifiable information or opt-out of receiving email communications from Company by sending an e-mail to us. You can also opt-out of receiving email communications from Company by clicking on the “unsubscribe” link in our emails. We will make a reasonable effort to accommodate your requests.

How We Communicate with You. We may send you communications about our Services, including push notifications through your digital wallet card (points updates, game reminders), promotional messages (where permitted by law), and service-related notices. You may opt out of promotional communications at any time.

Text Communications: If you provide us with your telephone number, including by creating an account, completing a form, downloading an application, or otherwise interacting with our Services, you may consent to receive commercial advertising communications from us as described below.

By providing your telephone number and, where required, taking an affirmative action such as checking a box or selecting “accept,” you provide your prior express written consent to receive calls and text messages from Company including calls or text messages delivered using an automatic telephone dialing system or artificial or prerecorded voice, at the telephone number you provided. These communications may include marketing, promotional, transactional, and informational messages, as applicable.

You acknowledge and agree to the following:

  • Voluntary Consent. You are not required to provide consent as a condition of purchasing any goods or services.
  • Scope of Communications. Communications may include marketing, advertising, promotional, account-related, or service messages, and may be sent by us or on our behalf by our service providers, affiliates, or marketing partners.
  • Use of Automated Technology. Messages may be sent using automated dialing systems or other automated technologies.
  • Message Frequency. Message frequency will vary based on your interactions with us.
  • Charges. Message and data rates may apply based on your mobile carrier and service plan.
  • Revocation of Consent. You may revoke your consent at any time by following the instructions in the applicable message (e.g., replying “STOP” to a text message) or by contacting us using the information provided below.

We will process your telephone number and related personal information in accordance with this Privacy Policy, including for the purpose of delivering communications and managing your preferences. We will not share your telephone number or your consent to receive communications with our affiliates or third parties other than service providers necessary to complete the communications.

Children Under the Age of 18

We do not knowingly collect personal information from children under the age of 18. If we become aware that we have inadvertently collected personal information from a child under 18, we will take reasonable steps to delete such information. If you believe that we have collected personal information from a child under 18, please contact us using the contact information provided below.

Our Use of Cookies and Other Tracking Mechanisms

We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Site. We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf).

Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.

  • Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity after you have logged in, as you move through our Site and Services.
  • Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.

Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site. We also may use other analytic means to evaluate our Site, and Services. We use these tools to help us improve our Site’s and Services’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons, session replay, or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Ad Networks. Users in the United States may opt out of many ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members. Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on a consumer choice website, your opt out may not be effective.

Global Privacy Control and Universal Opt-Out Signals

We recognize and honor browser-based privacy preference signals, including the Global Privacy Control (“GPC”). The GPC is a setting available in certain web browsers and browser extensions that allows users to automatically communicate their preference to opt out of certain data processing activities, such as the sale or sharing of personal information.

When we receive a GPC signal from your browser or device, we treat it as a valid request to opt out of the sale or sharing of your personal information, to the extent required by applicable law. This means that, where required, we will limit the use of your personal information for purposes such as cross-context behavioral advertising or similar activities.

You do not need to take any additional action to submit this request. The GPC signal is automatically transmitted by your browser when it is enabled.

Use of De-identified Data

We may use de-identified data, which cannot be linked to you or individuals using our services for the purposes of providing Services, product development, employee training, research and development and to gain insights on product improvement and other operational purposes that enhance our Services and your experiences with us. We take reasonable measures to ensure that our process of de- identifying information about you, and your use of the services cannot be associated or linked to you. When we share de-identified data with our service providers, partners or other third parties, we enter contracts that restrict the use of the data and the re-identification of the data to you and other users of our services.

How Long We Retain Your Information

We retain information about you only for as long as necessary to provide our Services, maintain our website, comply with applicable law, and contractual obligations. We may retain your personal information, posts, and service records for as long as you are a customer to provide you with the Services. Retention periods may vary depending on the type of information and the purpose for which it was collected.

Aggregated data is retained and used by Company for analysis, product improvement, and troubleshooting purposes. In some cases, social media content may continue to exist on the Social Networks even after you or we delete it from our Services, and you will need to contact the relevant Social Network directly if you would like to remove this content.

Disclosure of Your Information to Third Parties

We may disclose personal information that we collect, or you provide as described in this Privacy Policy:

  • To contractors, service providers and other third parties we use to support our business;
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, in which personal information held by us about Site’s users is among the assets transferred;
  • To fulfill the purpose for which you provide it;
  • For any other purpose disclosed by us when you provide the information; or
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law or legal process, including to respond to any government or regulatory request;
  • To enforce or apply the Company Terms of Use and other agreements, including for billing and collection purposes; or
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, Affiliates, our customers or others.

Third Party Links

  • Please be aware that our Sites and email communications may contain links to other websites on the Internet that are owned and operated by third parties. When you press these links, you are transferred to the websites of these third parties. The privacy and data processing practices of those websites are covered by the Privacy Policies of the operators of these sites, not our Privacy Policy. We encourage you to review the privacy policies of other websites to understand their privacy practices.

Additional California Disclosures

CCPA/CPRA RightExplanation of the Right
Right to Know / AccessConsumers may request disclosure of categories of PI collected, sources, purposes, categories of third parties, and specific pieces of PI.
Right to DeleteConsumers may request deletion of PI collected from them unless an exception applies.
Right to CorrectConsumers may request correction of inaccurate PI maintained by the business.
Right to Opt-Out of Sale or SharingConsumers may direct the business not to sell their PI or share it for cross-context behavioral advertising.
Right to Limit Use of Sensitive PIConsumers may limit use and disclosure of SPI to what is necessary to perform requested services or operations.
Right to Non-DiscriminationConsumers must not receive different prices, services, or treatment for exercising CCPA rights.
Right to Notice at CollectionConsumers must receive a Notice at Collection describing categories of PI, purposes, sale/sharing status, and retention.
Right to Opt-Out of ADMTConsumers may opt out of automated decision-making technology used for significant decisions.
Right to Access ADMT InformationConsumers may access information about logic, outputs, and effects of ADMT systems applied to them.
Right to Appeal ADMT DecisionsConsumers may appeal an ADMT-driven decision impacting them.
Right to Notice of Financial IncentivesConsumers must receive a notice explaining any financial incentives and terms if PI is exchanged for benefits.
Category of Personal Information CollectedPurpose(s) for Collection and UseCategories of Vendors / Third PartiesIs PI Sold or Shared?
IdentifiersAccount creation, service provision, communication, security, fraud preventionIT service providers, customer support vendors, cloud hosting providersYes
Sensitive Personal InformationIdentity verification, compliance, fraud preventionPayment processors, identity-verification vendors, security service providersNo
Customer Records InformationService delivery, billing, account managementCRM platforms, billing processors, service providersYes
Commercial InformationOrder fulfillment, analytics, service improvementPayment processors, analytics providers, logistics vendorsYes
Internet / Network ActivitySite functionality, security, analytics, advertisingCookie vendors, analytics tools, ad tech partnersYes
Geolocation DataService localizationSecurity vendors, analytics platformsNo
Audio/Visual/Electronic DataQuality control, support interactions, securityCustomer service platforms, communications vendorsNo
Professional or Employment InformationB2B relationship management, onboarding verificationCRM systems, verification toolsYes
Education InformationApplicant screening, credential verificationHR systems, verification vendorsYes
InferencesPersonalization, advertising, customer experienceAnalytics partners, ad tech partnersYes
  • ​Selling or Sharing of Personal Information

Our Practices

We may disclose personal information to certain third parties or service providers for purposes such as analytics, advertising, or other operational functions. Some of these disclosures may constitute a “sale” or “sharing” of personal information under California law.

Your Right to Opt Out

You have the right to opt out of the sale or sharing of your personal information at any time. You may exercise this right by:

  • Clicking the “Do Not Sell or Share My Personal Information” link located on our website; or
  • Enabling an opt-out preference signal, such as the Global Privacy Control (GPC), in your browser or device settings.

If we receive an opt-out request through either method, we will process the request in accordance with applicable law.

California Privacy Rights (Shine the Light Law)

California Civil Code § 1798.83 permits California residents with whom we have an established business relationship to request certain information regarding our disclosure of personal information to third parties for those third parties' direct marketing purposes during the immediately preceding calendar year. Under certain circumstances, we may disclose personal information to affiliates, business partners, advertising partners, or other third parties who may use the information for their own marketing purposes, subject to applicable law and contractual arrangements.

  • California residents may request information regarding:
  • The categories of personal information disclosed to third parties for their own direct marketing purposes; and
  • The names and addresses of the third parties that received such information.

To submit a Shine the Light request, please contact us at support@fanthrill.com with the subject line "California Shine the Light Request" or write to us at:

FanThrill LLC
[ADDRESS]

Security Measures

We use commercially reasonable measures for protection of our customer data. We will take reasonable measures which we believe are appropriate to protect your information from loss, misuse, alteration or destruction, and, where possible, will ask that any third parties to whom we may transfer your information take comparable steps to protect that security. Email is not a secure form of communication. Please do not send us any personally sensitive information via email.

Changes to the Privacy Policy

We may update the Privacy Policy from time to time by posting modifications to the Privacy Policy at the Site. By using the Site following such changes, you agree to be bound by such changes. Please check the Site periodically to familiarize yourself with any changes that may have been made to the Privacy Policy. You can determine when the Privacy Policy was last changed by checking the “Last Updated” reference above.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, email support@fanthrill.com.

FanThrill — You Make the Call.

Free-to-play sports prediction platform. No purchase necessary. Points have no cash value. Sweepstakes void where prohibited. Must be 18 years or older. Predictions are for entertainment purposes only. No money is ever at risk.

© 2026 FanThrill, LLC. All rights reserved.

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