Privacy Policy

This privacy policy explains how Fantasy Advantage Ltd. (“Fantasy”, or “us”, “our”, “we”) makes use of data and information received from, or about, our end users. If not specifically defined herein, capitalized terms have the meaning given to them in our Terms of Use (the “Terms”). The term “App” means the application on which this Privacy Policy is made available.

We respect the right to privacy of end users. Your ability to make informed choices about the use of your information is important to us. This privacy statement explains our policy regarding the collection, use, disclosure and protection of any information we receive.

1. Information We Collect

1.1. Information You Provide to Us.

1.1.1. The App may require users to register in order to use certain services provided therein. If you choose to register, you will be asked to provide us with certain personal information in the course of the registration process such as email address, name, username, etc.

1.1.2. If you send us a ‘Contact Us’ or similar request whether by use of an online form or email, or you submit a request to receive phone guidance on available promotions from our representatives, you may be required to provide us with certain personal information, such as your email address, name and phone number.

1.1.3. We may also offer you the opportunity to subscribe to newsletters and participate in surveys and other promotional activities (some of which may be administered by us, and some of which may be administered by third party services with which we engage). In each of the foregoing cases, your interaction (such as responding on the blog forum, subscribing to a newsletter, or participating in a survey) may require you to provide certain personal information such as your name and email address.

1.2. Information We Collect from You.

1.2.1. We may collect information that may be considered personal in the course of your use of the App, such as information about your laptop, tablet, mobile device and operating system, unique device identifier, software, your usage of the service, location data, time zone, browser type, Internet Protocol (IP) address, network Media Access Control (MAC), Geolocation (precise geolocation data is collected only with your prior consent), , language preference, referring pages, exit pages and URLs, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of this activity, behavior and movement in the App, whether you open, forward or click-through emails and ads, log files, and other usage data.

1.2.2. We also collect certain information such as information concerning the use of the tools we make available, including any teams or players that you pick and the

performance of those teams/players, information about purchases you made within our App, as well as statistical and aggregated information about your use of the App and our services.

1.2.3. The App uses “cookies” and other anonymous web tracking technologies (such as “web beacons” and “pixel tags”) that are developed by us or one of ours third party service providers.

1.3. Information We Receive from Third Parties

1.3.1. We may receive personal information about you from our third-party vendors or partners when you view our ad (whether promoting our App or one of our partners) in a third-party publisher website or mobile application. Such information includes: Internet Protocol (IP) address, DMA, connection speed, user agent, imprecise location (e.g. zip code, country, region), browser type, operating system, browser language, Internet Service Provider (ISP), click event as well as UUIDs that our vendors or partners assign to your browser or device (such as Google/Apple advertising identifiers associated with your browser or device, cookie ID, mobile advertising ID or statistical ID).

1.3.2. We may also receive personal information about you from our partners who are linked to in this App. Such information may include an internal user identifier that our system generates for each user (not a unique identifier), and the summary of actions taken by you on such partners’ websites or mobile applications (e.g. click, purchase, view, form submission). Such information obtained from our partners is used to measure or report our advertising performance.

1.3.3. We may receive information about you from Google, Facebook, or Apple if you choose to register or sign-in using their sign-in services. Such information may include, without limitation, your name, email address, language preference, and profile picture.

1.3.4. Betting Information obtained from Sharp Sports. Some of our Apps may offer you the functionality to synchronize your third-party sportsbook account with the App (“Bet Sync”). In order to offer the Bet Sync functionality, Fantasy uses Sharp Sports Inc. (a New Jersey corporation with its principal place of business at 111 Town Sq Pl, Jersey City, New Jersey) (“Sharp Sports”).

Upon you accessing the Bet Sync link placed on the App, providing Sharp Sports with your login credentials to the third-party sportsbook and consenting to the Sharp Sports’ terms and conditions and privacy policy, Sharp Sports will gather your third-party sportsbook account data and share with us the following categories of your data: (i) third-party sportsbook account data: your account’s cash/bonus balance, net profit and winning percentage; and (ii) information on your betting activity: bet type, bet name, bet odds, bet winning amount, bet status, bet placed time (collectively: “Sharp Sports Data”). Note that Fantasy never gets access to your login credentials from Sharp Sports – such credentials are processed solely on Sharp Sport’s servers. Please review Section 7 (“Third Parties”) of this Privacy Policy for additional details about Bet Sync.

2. How we Use Information

In addition to the uses described elsewhere in this Privacy Policy, we may also use your personal information for the following purposes:

2.1. We use all information provided to assist us with: diagnosing problems with our services, the development and improvement of our App, services, tools and associated technologies, and to develop new services, features and functionality, including through third parties such as contractors, sub-contractors and service providers.

2.2. By analyzing all information we receive, we may compile statistical information across a variety of users (“Statistical Information”). Statistical Information helps understand trends and customer needs so that new services can be considered and so our services and associated technology and services can be tailored to customer desires. We may share non-personal Statistical Information with our partners, pursuant to commercial terms that we determine in our sole discretion. In addition, we may otherwise provide any information to third parties, so long as we have removed any information that identifies any specific individual or user, such as a name, address or contact information.

2.3. We may use your information to contact you for administrative purposes such as customer service or to provide promotional messages. We may use your information in order to provide you with information or promotions that we believe you may be interested in, however you will always have the possibility to opt-out from direct communications containing commercial messages.

2.4. We may use your information to measure, report or assess our marketing campaigns performance (which may include campaigns that advertise our Apps and campaigns advertising third-party advertisers to whom we provide advertising services), to track referrals made through this App or through our ads placed on other websites or mobile applications, and to validate you as a human and not a bot.

2.5. We may use analytics tools, including Google Analytics, Smartlook and Amplitude. These tools help us understand users’ behavior on our App and services, including tracking page content, and click/touch, movements, scrolls, and keystroke activities. Click here and follow the instructions therein to opt-out of Google Analytics.

2.6. We use Sharp Sports Data in order to conduct targeted advertising, personalize your experience on the App and to improve and develop our products. Such purposes include: offering you tailored rewards and promotions within the App, providing you with personalized betting insights (such as bet types won the most, recommended bets, etc.), and displaying to you more relevant information within the App; facilitating your access to your third-party sportsbook account information from within the App; conducting direct marketing campaigns with relevant offers; and gaining analytics insights on our users’ betting activities and trends.

3. Cookies

We may use cookies, web beacons, gifs, pixel tags, log files, or other industry recognized technologies to automatically collect certain information when you use our App and services (collectively, “Cookies”) in order to help us learn about how you use the App and services and enhance your online experience.

Cookies are small text files containing strings of information that are locally stored on your computer or mobile device. They are widely used in order to make websites work, or work in a better, more efficient way. They can do this because websites can read and write these files, enabling them to recognize you and remember important information that will make your use of a website more convenient (e.g. by remembering your user preferences).

Check the “Help” menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences. Note that our system may not recognize some or all “Do Not Track” headers from browsers.

4. How we Protect Information

We follow generally accepted industry standards to protect the data submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

5. Sharing Your Information with Third Parties

We may use subcontractors and third-party service providers and send them information we receive for the purposes set forth in this Privacy Policy. Such subcontractors and third-party service providers are engaged to carry out certain tasks on behalf of Fantasy, including: maintaining our technology infrastructure, offering customer service (including through call centers), detecting fraud, serving ads, measuring ad performance, conducting research and surveys, distributing emails, analyzing how are products are used, and managing promotions. When performing such tasks, the subcontractors or service providers may have access to some of your information described above.

We may share your information with our subsidiaries, parents and/or affiliates for purposes consistent with this Privacy Policy. In addition, we may disclose or transfer data and information in connection with a sale of all or part of our business or assets, in the event of change of control of Fantasy (or any negotiation process with respect to these events) or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

We may disclose data and information as necessary for us to enforce our agreements with you, to investigate any claims against Fantasy, and to protect the rights and property of Fantasy or its agents, employees and customers. We may disclose data as we reasonably believe necessary to investigate and protect the security of our software, servers and other equipment.

Notwithstanding anything to the contrary herein, we will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or digital content of any user suspected to have engaged in illegal or infringing behavior. We will comply with any applicable law that requires the collection and provision of your data to the applicable authorities.

6. Children

Fantasy does not knowingly collect personally identifiable information from individuals under the age of 21.

7. Third Parties

This privacy policy does not cover information that you may independently provide to third parties by using links to third parties which may exist in our App. We have no control (or responsibility over such third-party products or websites). Accordingly, please review the privacy policy of any such third party in order to understand how they use, collect and store your information.

Fantasy uses Sharp Sports to gather your data from third-party sportsbooks. By using the Bet Sync feature, you grant Sharp Sports the right, power and authority to act on your behalf to access and transmit your personal information from your relevant third-party sportsbook account and the right, power and authority for Sharp Sports to share such information with Fantasy. Sharp Sport’s service is subject to their own privacy policy and terms and conditions, which can be reviewed at the following links: Sharp Sports Privacy Policy, and Sharp Sports Terms of Service.

We are not responsible for the privacy practices of Sharp Sports or any third-party linked from the App.

8. Notice to Virginia and Colorado Residents.

If you are a Virginia or Colorado resident, this section may apply to you and supplement the main privacy policy. The Virginia Consumer Data Protection Act and Colorado Privacy Act provide specific rights to Virginia and Colorado residents in relation to their personal information. As a Virginia or Colorado resident and to the extent provided by law, you may:

· Request to Know/Access. You have a right to confirm whether or not we are processing any of your personal data and to access such personal data. See below instructions on how to exercise this right.

· Request to Correct Inaccuracies. You have a right to request us to correct any inaccuracies in your personal data as retained by us. See below instructions on how to exercise this right.

· Request to Deletion. You have a right to request that we delete from our databases any of your personal data that we collect and retain, subject to certain exceptions (such as detecting security incidents, debugging, compliance with legal obligations, etc.).

· Request to Opt-out from Targeted Advertising or Sale of personal information. You have a right to opt-out from our sharing or processing of your information for targeted advertising purposes, and to opt-out from our selling of your information to third parties. Note that you may still receive advertising, including personalized ads based on your activity within the App.

You may request to exercise the rights detailed in this section by sending us an email at info@fantasyadvantage.com detailing the rights you would like to exercise.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If the exercise of your rights requires more time (up to 45 additional days), we will inform you of the reason and extension period in writing. Prior to responding to any requests, we may require you to verify your identity. We may deny your request if we could not verify your request or if we must retain your personal information for certain activities permitted by law (such as detecting security incidents, debugging, comply with legal obligations, etc.).

To the extent your request has been rejected and you wish to appeal our decision, you may send your appeal at info@fantasyadvantage.com within 30 days from the date our decision has been sent to you. Within 60 days of our receipt of your appeal, we will inform you via an email of our decision.

9. Changes

We reserve the right to update this Privacy Policy from time to time. If so, we will post the updated Privacy Policy on the App. We encourage you to review this Privacy Policy regularly for any changes. Your continued use of our services and the App will be subject to the then-current privacy policy. If any modification is unacceptable to you, you may cease using the services and the App at any time. If you do not cease using the services and the App, you will be deemed to have accepted those modifications.

10. Comments and Questions

If you have any comments or questions about our privacy policy, please contact us at info@fantasyadvantage.com.

Last updated: 9 July 2023