Privacy Policy

1About This Policy

This Privacy Policy explains how BetFully, Inc., a Delaware corporation located at 6965 El Camino Real, Suite 105 #680, Carlsbad, California 92009 ("BetFully," "we," "us," or "our"), collects, uses, discloses, and protects personal information.

This Policy is incorporated into and forms part of our Terms of Service. Capitalized terms not defined here have the meanings given in the Terms of Service. Where this Policy describes your rights, those rights are in addition to, and not limited by, the Terms of Service.

We wrote this Policy to be read. Where a legal term is unavoidable, we explain it in plain language the first time it appears.

2Scope: What This Policy Covers

2.1 Covered services. This Policy applies to:

• the website at LineStarApp.com and related sites and subdomains we operate;
• the LineStar applications for iOS and Android;
• the Optimizer, projections, analytics, props tools, exports, chat and community features, alerts, and other functionality we provide; and
• our email, SMS, push, and support communications.

Collectively, the "Services."

2.2 What this Policy does not cover. This Policy does not apply to:

• Third-party platforms. Sportsbooks, daily fantasy sports operators, and other sites you reach through links on the Services — including affiliate links — operate under their own privacy policies. See Sections 8 and 19.
• App stores. Apple and Google collect information when you download, purchase, or subscribe through their platforms, governed by their own policies.
• Other BetFully products. TrackWiz and Props Optimizer have their own privacy policies.

2.3 Your consent. By using the Services, you acknowledge that you have read this Policy. Where the law requires consent for a specific processing activity, we obtain that consent separately rather than treating your use of the Services as consent.

3Information We Collect

3.1 Information you provide directly

3.2 Information collected automatically

3.3 Information from third parties

• App stores. Apple and Google provide subscription status, renewal and cancellation events, refund events, and an anonymized transaction identifier. They do not give us your full payment card details.
• Payment processor. Our processor confirms transaction success or failure and returns partial card details for your receipt and account display.
• Analytics and attribution providers. Aggregated and device-level usage information as described in Section 7.
• Advertising partners. Where we display advertising, ad networks may provide limited measurement and attribution data.
• Affiliate networks. Conversion and commission data confirming that a referral occurred. This generally identifies the referral, not your activity on the partner's platform.
• Sports data providers. Statistics, odds, injury, and slate data. This is information about athletes and games, not about you.
• Fraud and security providers. Signals indicating suspicious access, credential sharing, bot activity, or scraping.
• Social sign-in. If you sign in with a third-party account, that provider shares your email address and basic profile as permitted by your settings there.

4What We Do Not Collect

We think it is as important to say what we do not gather as what we do. We do not collect:

• Full payment card numbers, bank account numbers, or CVV codes. These go directly to Apple, Google, or our PCI-compliant payment processor. We never see or store them.
• Social Security numbers or government identification numbers, except a taxpayer identification number if you enroll in a Referral Program and we must issue a tax form.
• Precise GPS or background location.
• Contacts, photo library, microphone, or camera content, unless you attach a file to a support request.
• Biometric identifiers, including face or fingerprint data. Where you unlock the app with Face ID or Touch ID, that verification happens on your device and the result is never transmitted to us.
• Health, genetic, or medical information.
• Information about your wagers, deposits, withdrawals, or account balances on any third-party sportsbook or DFS platform. We have no access to those accounts.
• Information from anyone we know to be under 18.

5Cookies, SDKs, and Similar Technologies

5.1 On the web. We use cookies, local storage, and pixels in four categories:

• Strictly necessary — authentication, session management, security, load balancing, and fraud prevention. These cannot be disabled without breaking the Services.
• Functional — remembering your sport, slate, layout, and display preferences.
• Analytics — understanding which features are used and where people encounter problems.
• Advertising — measuring ad performance and, where applicable, delivering relevant advertising.

5.2 In the apps. Mobile apps do not use browser cookies. They use software development kits (SDKs) and device identifiers that serve equivalent purposes.

5.3 Your controls. Browser settings let you block or delete cookies; blocking strictly necessary cookies will prevent you from signing in. On iOS, App Tracking Transparency governs whether apps may access your IDFA — if you decline, we do not use it. On Android, you can reset or delete your Advertising ID in system settings. See Section 11 for the full list of opt-outs.

5.4 Global Privacy Control. Where you send a Global Privacy Control (GPC) or comparable opt-out preference signal from your browser, we treat it as a valid request to opt out of the sale and sharing of personal information for that browser, as described in Section 10.

6How We Use Your Information

6.1 Automated decision-making. We do not use your personal information to make automated decisions producing legal or similarly significant effects about you. The Optimizer generates sports projections; it does not profile you.

6.2 No use for AI training on your content. We do not use your User Content, chat messages, or support communications to train third-party artificial intelligence or machine learning models, and we do not license your User Content to any third party for that purpose.

7Advertising and Analytics

7.1 Analytics. We use analytics and crash-reporting tools to understand usage and diagnose problems. These tools collect the device, log, and usage information described in Section 3.2 and may set their own identifiers.

7.2 Advertising. Free and ad-supported tiers of the Services may display advertising served by third-party ad networks. Those networks may collect device identifiers, IP address, and interaction data to select and measure advertising, including across other apps and websites — what state privacy laws call cross-context behavioral advertising.

7.3 Paid subscribers. Where a paid Subscription is advertised as ad-free, we do not serve third-party advertising to that account.

7.4 Named providers. A current list of the analytics, attribution, and advertising providers we use is maintained at LineStarApp.com/privacy/providers and updated when the list changes.

7.5 Your controls. See Section 11.

8Affiliate Links and Partner Tracking

Section 15 of our Terms of Service discloses that we earn compensation from certain third-party links. Here is what that means for your data.

8.1 What happens when you click. Clicking an affiliate link takes you to a third party's website or app. In the process:

• the third party receives your IP address, browser or device information, and a tracking parameter identifying BetFully as the referrer;
• the third party may set its own cookies or identifiers on your device; and
• from that point forward, the third party's privacy policy governs — not ours.

8.2 What we receive back. Affiliate networks report conversions to us — typically that a referral registered or transacted, with a timestamp and a commission amount. We do not receive your deposits, wagers, balances, betting history, or account details on any partner platform, and we do not want them.

8.3 Your choice. You are never required to use an affiliate link. Navigating directly to a partner's site produces no referral data.

9How We Disclose Your Information

We disclose personal information only in the circumstances below. We do not disclose your personal information to data brokers.

9.1 Service providers. Companies that perform functions on our behalf under written contracts limiting their use of the information to providing services to us: cloud hosting and storage, payment processing, subscription management, email and push delivery, customer support tooling, analytics, crash reporting, security and fraud prevention, and accounting.

9.2 Advertising partners. As described in Section 7, where applicable.

9.3 Affiliate partners. As described in Section 8, when you click a link.

9.4 App stores. Apple and Google, for subscription management, refunds, and entitlement verification.

9.5 Community visibility. Chat messages, comments, and community posts are visible to other users along with your display name and avatar. Do not post anything in community features you would not want publicly associated with you.

9.6 Legal and safety. We may disclose information where we reasonably believe it is necessary to: comply with a law, subpoena, warrant, court order, or other lawful request; enforce our Terms of Service, including the anti-scraping and intellectual property provisions in Sections 9 and 10; investigate suspected fraud, security incidents, or violations; establish, exercise, or defend legal claims, including patent and trademark enforcement; or protect the rights, property, or safety of BetFully, our users, or the public.

We review each request for legal validity and scope, and we object to requests that are overbroad or defective. Where we are legally permitted to notify you of a request for your information, we will make reasonable efforts to do so.

9.7 Corporate transactions. In connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our business, personal information may be transferred as a business asset. Any acquirer will remain bound by this Policy with respect to information transferred, unless and until you are notified of and consent to a material change.

9.8 Aggregated and de-identified information. We may create and disclose aggregated or de-identified information — for example, how many users ran the Optimizer for a given slate — that cannot reasonably be used to identify you. We maintain de-identified information in de-identified form and do not attempt to re-identify it.

9.9 With your direction. Where you ask us to share information with someone else.

10Sale and Sharing of Personal Information

10.1 We do not sell your personal information for money. We have never exchanged user information for cash payment and do not intend to.

10.2 The legal caveat, stated plainly. California and several other states define "sell" and "share" more broadly than everyday usage. Under those definitions, using third-party advertising and analytics technologies that transmit device identifiers or usage data to those providers may constitute a "sale" or a "share" for cross-context behavioral advertising — even though no money changes hands. We disclose this rather than rely on the narrow everyday meaning of "sell."

10.3 What may be involved. Where this applies, the categories are identifiers (including device and advertising identifiers), internet and network activity information, and inferences. It does not include your password, payment information, support communications, or content of private messages.

10.4 We do not sell or share the personal information of minors. We do not knowingly have users under 18, and we do not knowingly sell or share the personal information of consumers under 16.

10.5 How to opt out. Use any of the following:

• "Do Not Sell or Share My Personal Information" in the footer of LineStarApp.com and in the app's privacy settings.
• Global Privacy Control, which we honor automatically as a browser-level opt-out.
• iOS: decline tracking when prompted, or turn off Settings › Privacy & Security › Tracking.
• Android: turn on "Delete advertising ID" or "Opt out of Ads Personalization" in system settings.
• Email us at Support@BetFully.com with the subject line "Opt Out."

An opt-out submitted through a browser or device applies to that browser or device. Signing in lets us apply it to your account across devices.

11Your Privacy Choices and Opt-Outs

Transactional messages. You cannot opt out of billing, security, and legal notices while you maintain an account. If you no longer wish to receive these, close your account.

12Your Privacy Rights and How to Exercise Them

12.1 Rights we extend to everyone. Several states grant privacy rights to their residents. Rather than operate a two-tier system, we extend the following rights to all users of the Services, wherever you live:

• Know and access — what personal information we hold about you, where it came from, why we process it, and to whom we have disclosed it.
• Portability — receive your information in a portable, machine-readable format.
• Correct — fix inaccurate personal information.
• Delete — have your personal information deleted, subject to the exceptions in Section 12.4.
• Opt out of the sale or sharing of personal information and of targeted advertising.
• Limit the use of sensitive personal information (Section 13.4).
• Non-discrimination — we will not deny service, charge a different price, or provide a lesser experience because you exercised a privacy right. We offer no financial incentive programs in exchange for personal information.

12.2 How to submit a request. Email Support@BetFully.com with the subject line "Privacy Request" and state which right you are exercising. Some requests can also be completed directly in your account settings, which is faster.

12.3 Verification. To protect your information, we verify requests before acting. For account holders, we generally verify by confirming control of the email address on the account, and we may ask you to confirm details only the account holder would know. We will not ask you for your password, and no BetFully employee will ever request it. If we cannot verify your identity, we will tell you and explain why.

12.4 Timing and exceptions. We respond within 45 days, and may extend once by another 45 days where reasonably necessary, with notice to you. We may decline all or part of a request where an exception applies — for example, where we must retain information for tax, accounting, security, fraud prevention, or legal-claim purposes, where deletion would compromise another person's privacy or the integrity of a community discussion, or where the request is manifestly unfounded or excessive. When we decline, we tell you which exception applies. Requests are free unless excessive or repetitive.

12.5 Authorized agents. You may use an authorized agent, who must provide written permission signed by you; we may also ask you to verify your identity directly.

12.6 Appeals. If we deny your request, you may appeal by replying to our decision with the subject line "Privacy Appeal." We will respond within 45 days with our decision and reasoning. If we deny the appeal, we will tell you how to contact your state attorney general.

12.7 What deletion means. On an account deletion request, we delete or de-identify your account, profile, preferences, saved lineups, and usage history. We retain the records described in Section 17 where a legal exception applies. Community posts may remain visible in de-identified form to preserve the coherence of past conversations; tell us in your request if you want them removed as well and we will do so where feasible.

13California Privacy Disclosures

This Section supplements the rest of this Policy for California residents under the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA").

13.1 Categories. The categories of personal information we collect, the sources, the purposes, and the categories of third parties to whom we disclose each are set out in Appendix A.

13.2 Retention. We do not retain personal information longer than reasonably necessary for the purposes described in Section 6. Our retention schedule is in Section 17.

13.3 Your rights. California residents have the rights to know, access, delete, correct, opt out of sale and sharing, limit the use of sensitive personal information, and be free from discrimination. Section 12 explains how to exercise each.

13.4 Sensitive personal information. The only category of sensitive personal information we collect is account log-in credentials in combination with a password. We use this solely to authenticate you and secure your account — a use that falls within the exemptions in CCPA Regulations § 7027(m), meaning there is no additional use to limit. We do not use or disclose sensitive personal information to infer characteristics about you.

13.5 Shine the Light. California Civil Code § 1798.83 permits residents to request information about disclosures of personal information to third parties for their own direct marketing purposes. We do not make such disclosures.

13.6 Minors. We do not knowingly collect personal information from anyone under 18, and we do not sell or share the personal information of consumers under 16.

13.7 Metrics. Where we are required to publish annual request metrics, we will do so at LineStarApp.com/privacy/metrics.

14Other U.S. State Privacy Disclosures

14.1 States with comprehensive privacy laws. Residents of states including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, and Rhode Island have rights to confirm processing, access, correct, delete, obtain a portable copy, and opt out of targeted advertising, sale, and certain profiling. Section 12 describes how to exercise these rights and how to appeal a denial, and we extend them to all users regardless of state.

14.2 Sensitive data. Several of these laws require opt-in consent before processing sensitive data. We do not process the categories those laws define as sensitive — racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, citizenship or immigration status, genetic or biometric data, or precise geolocation.

14.3 Data protection assessments. Where required, we conduct and document assessments for processing that presents heightened risk.

14.4 Nevada. Nevada residents may direct us not to sell certain covered information. We do not sell covered information as Nevada defines it, but you may submit a request to Support@BetFully.com with the subject line "Nevada Opt-Out."

15Users Outside the United States

15.1 Where processing happens. BetFully operates in the United States, and our service providers process information in the United States and other countries. If you access the Services from outside the United States, your information will be transferred to and processed in the United States, where privacy laws may differ from those of your country.

15.2 Intended audience. The Services are directed to users in the United States. We do not target the Services to the European Economic Area, the United Kingdom, or Switzerland.

15.3 If you are in the EEA, UK, or Switzerland. Where the GDPR or UK GDPR applies to our processing, BetFully is the controller, and:

• Legal bases: performance of a contract (providing the Services and billing); legitimate interests (security, fraud prevention, product improvement, and enforcing our rights, balanced against your interests); consent (marketing and non-essential cookies, which you may withdraw at any time); and legal obligation.
• Your rights: access, rectification, erasure, restriction, portability, objection to processing based on legitimate interests, and withdrawal of consent. You may lodge a complaint with your supervisory authority.
• Transfers: we rely on Standard Contractual Clauses or another lawful mechanism for transfers out of the EEA or UK.

Contact Support@BetFully.com with the subject line "GDPR Request."

15.4 Canada. Canadian users may access and correct their personal information and may complain to the Office of the Privacy Commissioner of Canada.

16Children and Minors

The Services are intended for adults aged 18 and over. They are not directed to children, and we do not knowingly collect personal information from anyone under 18.

If we learn that we have collected personal information from a person under 18, we will delete it and terminate the account promptly. If you believe a minor has provided us with personal information, contact Support@BetFully.com with the subject line "Minor Account" and we will investigate.

Because we do not knowingly collect information from children under 13, the Children's Online Privacy Protection Act's parental-consent obligations do not apply to us. Our advertising partners are instructed not to treat our Services as directed to children.

17Data Retention

We keep personal information only as long as needed for the purposes in Section 6, then delete or de-identify it.

18Security

18.1 What we do. We maintain administrative, technical, and physical safeguards appropriate to the sensitivity of the information, including encryption in transit (TLS), encryption at rest for stored account data, hashed and salted passwords, role-based access limited to personnel who need it, logging and monitoring, and periodic review of our practices and vendors.

18.2 What you should do. Use a strong, unique password. Do not share your credentials — Section 6.4 of our Terms of Service prohibits it, and sharing is the single most common cause of account compromise. Notify us immediately at Support@BetFully.com if you suspect unauthorized access.

18.3 An honest limitation. No method of transmission or storage is completely secure. We cannot guarantee absolute security, and we do not claim to.

18.4 If a breach occurs. If a breach affecting your personal information occurs, we will notify you and the appropriate regulators as required by applicable law, without unreasonable delay, and will tell you what happened, what information was involved, and what steps we and you can take.

19Third-Party Services and Links

The Services contain links to third-party websites and applications, including sportsbooks, daily fantasy sports operators, data providers, and affiliate partners. We do not control those parties and are not responsible for their privacy practices. Their collection and use of your information is governed by their own policies, which we encourage you to read before providing information to them.

The presence of a link is not an endorsement. See Section 14 of our Terms of Service.

20Communications and Notifications

20.1 Transactional. Billing, security, account, and legal notices are necessary to the service and cannot be turned off while your account is open.

20.2 Marketing email. Sent only where you have not opted out. Every marketing email contains an unsubscribe link, honored promptly.

20.3 Push notifications. Sent only if you grant permission. Manage them in your device settings or in-app preferences.

20.4 SMS. Sent only if you provide a mobile number and opt in. Message and data rates may apply. Reply STOP to cancel or HELP for help. Consent to marketing texts is never a condition of purchase.

21App Store Privacy Disclosures

Apple requires a privacy "nutrition label" on the App Store and Google requires a Data Safety section on Google Play. Those disclosures summarize this Policy; this Policy is the authoritative and more detailed statement. If you notice a discrepancy between a store listing and this Policy, please tell us at Support@BetFully.com so we can correct the listing.

22Changes to This Policy

We may update this Policy. When we do, we will revise the "Last Updated" date and post the new version here.

If we make a material change — for example, collecting a new category of information, using information for a materially different purpose, or disclosing it to a new category of recipient — we will provide prominent advance notice by email, in-app notice, or a banner on the Site before the change takes effect, and, where the law requires consent, we will obtain it.

We maintain prior versions of this Policy at LineStarApp.com/privacy/archive so you can see what changed and when.

23Contact Us

BetFully, Inc. 6965 El Camino Real, Suite 105 #680 Carlsbad, California 92009 United States

Email: Support@BetFully.com Phone: (920) 474-6634

For faster handling, use one of these subject lines: "Privacy Request", "Privacy Appeal", "Opt Out", "Nevada Opt-Out", "GDPR Request", or "Minor Account".

We respond to privacy inquiries within 45 days, and usually much sooner.

24Appendix A — Categories of Personal Information

Categories are those enumerated in the CCPA. "Disclosed to" lists the categories of recipients described in Section 9.

Sources of collection: directly from you; automatically from your device and use of the Services; and from the third parties listed in Section 3.3.

Business and commercial purposes: as set out in Section 6.