Fliff Inc. (“Fliff” or “we”, “our” or “us”) operates the Fliff platform, which includes the Fliff app and website, and all related channels of communications and social media pages (the foregoing, and all content, features, and materials thereon, shall hereinafter be collectively referred to as the “Platform”).
We believe that the privacy and security of your Personal Information is very important. This Privacy Policy (“Policy”) explains the types of Personal Information we collect from users of the Platform, how that Personal Information is used, how the Personal Information may be disclosed to other parties, and what choices our users have regarding their Personal Information. We encourage you to read this Policy carefully.
Any updates or modifications to this Policy will be posted in our mobile app and website. By using or accessing the Platform, you signify that you have read, understand and agree to be bound by this Policy.
This Policy is effective as of April 2, 2026.
PERSONAL INFORMATION WE COLLECT
The term “Personal Information” includes any data that identifies or could reasonably be associated with an individual person, directly or indirectly. Anonymous information and information that has been de-identified, such that it cannot reasonably be linked to or used to infer information about an individual, is not Personal Information. When we process de-identified information, we maintain and use the information in de-identified form, and do not attempt to re-identify the information, except as permitted by applicable law.
We may process the following types of Personal Information through our Platform:
- Contact Information, such as your name, e-mail address, physical address, and phone number.
- Account Information, such as username and credentials, information you add to your account, and information received from third-party services or platforms that you link to your account.
- Identification Documentation, such as driver’s license, social security number, or other government issued identification documents, which our service providers may process on our behalf for identity verification purposes.
- Financial Information, such as your method of payment; financial account number, debit or credit card number, or any part thereof; receipts from your transactions; and transaction details, including amount or quantity.
- Communications and Chats, such as any support communications; messages or information you share or receive through the chat feature; date, time, and metadata associated with your chat messages; and user identifiers and profile information of chat participants.
- Device Information, which is information relating to the device you are using when you access our Platform, such as your device’s IP address, your device identifiers (including Apple IDFA or an Android Advertising ID), the type of browser and operating system you are using, the identity of your internet service provider, WiFi connections, and your device and browser settings. Device Information may include information obtained through automatic analytics and tracking technologies, such as cookies, web beacons, mobile device identifiers, or SDKs. You may change your preferences regarding the collection and use of some identifiers in your device settings.
- Usage Data, which is data related to your use of the Platform such as the pages you visit; your actions within the Platform; the type of content you have accessed, seen, forwarded and/or clicked on; date and time stamps; log files; and diagnostic, crash, and performance logs and reports.
- Geolocation Information, such as your device’s precise geolocation information and approximate location information. To access the Platform, precise geolocation access needs to be enabled. If you wish to disable location access, you can do so through your device settings, however, this will prevent you from being able to access the Platform.
- Biometric Data, such as scans of facial features derived from photos or images of your face, if you choose to provide them. With your consent, Biometric Data may be collected and processed for the purpose of identity verification by our service provider Persona.
Some of the information we process, such as information contained in government issued identification documents, and precise geolocation information, may be classified as “Sensitive Personal Information” under the laws of some jurisdictions. We use Sensitive Personal Information to operate the Platform, to demonstrate legal and regulatory compliance, and for legal, safety, fraud, and security purposes. Where legally required, we will collect and process Sensitive Personal Information only with your consent or for permissible business purposes under applicable law. We do not use Sensitive Personal Information for targeted advertising and do not “sell” or “share” Sensitive Personal Information under applicable data protection and privacy law.
HOW WE COLLECT OR RECEIVE PERSONAL INFORMATION
We may receive the Personal Information described above from the following sources:
- From you, such as when you create an account, make purchases, submit identity verification documentation, use the chat feature, make sports picks, participate in promotions, contact customer support, or otherwise interact with the Platform.
- Automatically from your device, when you access the Platform on your web browser or in our app.
- Through cookies and similar technologies, when you access our Platform, we may receive information about you from or through automatic technologies, such as cookies, pixels, web beacons, or software development kits (SDKs).
- From our service providers, such as our identity verification provider, payment processors, and analytics providers.
- From our advertising and marketing partners, such as ad networks, attribution providers, and demand-side platforms that may provide us with information about your interactions with advertisements for the Platform on third-party sites or services.
- From a third-party platform, if you choose to connect your account or log in to the Platform using a third-party service.
- From other parties, including when another user interacts with you through the chat feature or refers you to the Platform, or when someone otherwise provides information about you in connection with your use of the Platform.
HOW WE USE PERSONAL INFORMATION
We may process the Personal Information described above for the following purposes:
- To operate the Platform, including to provide you with the features and functionality, such as to enable you to create and manage your account; to process your sports picks and display your results; to maintain leaderboards, rankings, and achievement badges; and to facilitate the chat feature. Please note that chat contents are not encrypted end-to-end, and system administrators and vendors involved in delivering the chat service may have the ability to access chat content as required to operate and troubleshoot the systems.
- To communicate with you, including by responding to your inquiries and customer support requests; sending you account-related communications; and sending you promotional communications such as newsletters and emails about offers, rewards, and new features. You may opt out of promotional communications by clicking unsubscribe at the bottom of the email.
- To facilitate transactions, including to process purchases of Fliff Coins packages, manage your Fliff Coins and Fliff Cash balances, process prize redemptions and withdrawals, verify payment methods, and maintain transaction records.
- To personalize your experience, such as by customizing the content, features, and promotions you see; and providing tailored sports picks, odds, and recommendations.
- To advertise and promote the Platform, including by serving advertisements for the Platform on third-party sites and services; measuring the performance and reach of our advertising campaigns; attributing new user acquisitions to advertising sources; and delivering interest-based advertising.
- To develop, analyze, and improve the Platform, such as optimizing the Platform, generating statistics and analytics, improving the platform, troubleshooting errors, and conducting research and development.
- For safety, security, legal, and compliance purposes, including to guard against potential fraud; comply with applicable laws and regulations; investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and in connection with the enforcement of our Terms of Use and other agreements.
OUR DISCLOSURE OF PERSONAL INFORMATION
We may disclose your Personal Information in the following instances:
- To our service providers, who we engage to assist with operating the Platform, including to provide identity verification services, provide geofencing services, fix app crashes and errors, facilitate communication with users, and conduct payment processing.
- To our advertising partners, such as ad networks, attribution providers, and advertising measurement services to facilitate advertising for the Platform on third-party sites and services, measure the effectiveness of advertising campaigns, and provide you with advertising that may be relevant to your interests.
- To social networks and third-party platforms, if you choose to use social sharing features, connect your account to a social network, or interact with our Platform through a third-party service.
- To other users, in connection with the Platform's social features.
- To other parties, including to provide products or services, with your consent or at your direction.
- To government authorities or where legally required or permitted, in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law.
- To parties and persons in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
RETENTION AND SECURITY
We retain Personal Information for as long as reasonably necessary for the purposes described in this Policy. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We take reasonable precautions to protect your Personal Information against loss, misuse, unauthorized disclosure, alteration, and destruction. However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any Information that you transmit to us or from us, and you do so at your own risk. If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at privacy@getfliff.com.
IDENTITY VERIFICATION
Biometric Data may be processed for identity verification purposes, fraud prevention, and compliance with our legal obligations.There is no requirement within the Platform to grant us the use of your Biometric Data, and we will obtain your consent, prior to collecting, utilizing and/or processing such data.
We may ask you to upload a selfie-style photo and/or a photo of your government ID. Those images go directly to Persona Identities, Inc. (“Persona”), one of our service providers. Persona processes these images, including by generating data about your facial geometry (which may be considered to be Biometric Data in some jurisdictions) for the purposes of verifying your identity and preventing fraud. This may involve comparing data that may be considered to be Biometric Data such as the data generated from your selfie to the data generated from your ID, as well as comparing the data generated from your images to the data generated from other images.
Notwithstanding terms in this policy pertaining to other forms of Personal Information, Biometric Data will be permanently deleted by Persona when it is no longer needed to fulfill the purposes of identity verification and fraud prevention, or within two years, whichever is sooner. Persona relies on service providers to process the Biometric Data and other information for these purposes. For more information on Persona’s policies, please visit Persona’s Privacy Policy (https://withpersona.com/legal/privacy-policy).
Persona sends us the results of this screening but not the Biometric Data used to perform it. We do not collect or have access to the Biometric Data generated by Persona to perform these services.
AGE REQUIREMENTS
The Platform is not intended for or directed to people under the age of 18. You must confirm you are 18 years or older to access the Platform. In the event that we have actual knowledge that you are under the age of 18, we will deactivate your account and delete your information subject to safety, security, legal, or other compliance considerations. If you are a parent or guardian of someone under 18 years of age and you believe we have collected such information, please contact us at privacy@getfliff.com.
PRIVACY RIGHTS AND CHOICES
Depending on your jurisdiction, and subject to certain exceptions, exemptions, and restrictions, your rights may include:
- Know / Access. You may have the right to request access to your Personal Information, including the categories of Personal Information we have collected about you, categories of sources, purposes of processing, and categories of third parties to whom it has been disclosed. This right includes the ability to confirm whether we process any Personal Information about you.
- Deletion. You may have the right to ask us to delete your Personal Information, although this may impact your ability to use the Platform. Please note that we may retain Personal Information subject to safety, security, legal, or other compliance considerations.
- Correction. You may have the right to correct the Personal Information that we hold about you.
- Opt-Out of Sale and Share (Targeted Advertising or Ad Personalization). You may have the right to opt out of the "sale" or "sharing" of your Personal Information, or the use of your Personal Information for targeted advertising, as those terms are defined under applicable law. You may limit certain advertising-related disclosures by adjusting your device and browser settings, including:
- Mobile advertising ID. You can reset or limit ad tracking through your device settings (e.g., "Limit Ad Tracking" on iOS or "Opt out of Ads Personalization" on Android).
- Browser cookies. You can configure your browser to block or delete cookies. Please note that disabling cookies may affect Platform functionality.
Fliff will not discriminate against you for exercising any of your applicable rights. We reserve the right to deny your request if we cannot verify your identity or if an exemption or exception applies.
How to Exercise Your Rights
To submit a privacy request, please email us at privacy@getfliff.com with "Privacy Request" in the subject line. Please specify which right you wish to exercise and provide sufficient information for us to locate your account (e.g., your name, phone number, or email address). We will respond to your request within the timeframe required by applicable law. If we require additional time, we will notify you of the reason and the extension period.
Authorized Agents
You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.
LINKS TO THIRD-PARTY SITES
Our Platform may link to other third-party websites that are not controlled by Fliff, such as when you engage in social sharing features that allow you to “Share” or “Like” on a social network. These third parties are not under our control and we are not responsible for their privacy policies or practices. If you provide any Personal Information to any third party or through any such third-party websites, it will be subject to the privacy policies and practices of that third party.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to change this Policy at any time. In the event we make changes to this Policy, such a policy will be re-posted in the “Privacy” section of our Platform with the date such modifications were made indicated on the top of the page. Therefore, please review this Policy from time to time so that you are aware when any changes are made to this Policy.
GENERAL
If you have questions or comments about this Policy, please contact us at privacy@getfliff.com with “Privacy” in the subject line of your email or through the customer support contact form on the Platform.
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