JOLTRY SPORTS PRIVACY POLICY

Last Updated: 2026-01-01

Effective Date: 2026-01-01


1. INTRODUCTION

Joltry Sports Inc. (“Joltry Sports,” “Company,” “we,” “us,” “our”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, mobile application, and related services (collectively, the “Platform”).

This Privacy Policy applies to all users of the Platform located in the United States. By accessing or using the Platform, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Platform.

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated Privacy Policy on the Platform with a new “Last Updated” date and, where required by law, by email. Your continued use of the Platform after such changes constitutes your acceptance of the revised Privacy Policy.


2. INFORMATION WE COLLECT

We collect information in several ways: directly from you, automatically when you use the Platform, and from third-party sources.

2.1 Information You Provide to Us

Account Registration Information:
When you create an account, we collect your legal name, date of birth, email address, phone number, residential address, username, and password.

Identity Verification Information:
To comply with legal requirements and prevent fraud, we collect government-issued identification documents (such as driver’s license, passport, or state ID), proof of address documents, the last four digits of your Social Security Number, and a selfie photograph for identity matching purposes.

Financial Information:
When you make deposits or withdrawals, we collect bank account information, transaction history, and payment method details. We do not store complete bank account credentials; these are processed by our third-party payment processors.

Contest and Gameplay Information:
We collect information about the contests you enter, your picks and selections, winnings and losses, and your contest history.

Communications:
When you contact us for customer support or otherwise communicate with us, we collect the contents of those communications, including any attachments or information you provide.

Responsible Gaming Information:
If you use our responsible gaming tools, we collect information about your self-imposed limits, cooling-off periods, and self-exclusion requests.

2.2 Information Collected Automatically

Device and Browser Information:
We automatically collect information about your device, including device type, operating system, unique device identifiers, browser type and version, and mobile network information.

Location Information:
We collect precise geolocation data to verify that you are located in a jurisdiction where our Services are available. We may also collect approximate location information derived from your IP address.

Usage Information:
We collect information about how you interact with the Platform, including pages viewed, features used, links clicked, time spent on pages, and referring URLs.

Log Data:
Our servers automatically record information when you access the Platform, including your IP address, access times, and system activity.

Cookies and Similar Technologies:
We use cookies, pixel tags, web beacons, and similar technologies to collect information about your browsing activities. See Section 6 for more information about our use of cookies.

2.3 Information from Third Parties

Identity Verification Providers:
We receive verification results and risk assessments from third-party identity verification services.

Payment Processors:
We receive transaction confirmation and limited account information from our payment processing partners.

Sports Data Providers:
We receive statistical data about sporting events and athletes from third-party data providers. This data does not include your personal information.

Analytics Providers:
We receive aggregated analytics data from Google Analytics about Platform usage patterns.


3. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

3.1 Providing and Improving Our Services

3.2 Legal Compliance and Security

3.3 Communications

3.4 Analytics and Research


4. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information to third parties. We may share your information in the following circumstances:

4.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

Our service providers are contractually obligated to use your information only for the purposes of providing services to us and to maintain appropriate security measures.

4.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid legal requests, including:

4.3 Protection of Rights

We may disclose your information when we believe it is necessary to:

4.4 Business Transfers

If Joltry Sports is involved in a merger, acquisition, sale of assets, bankruptcy, or other business transaction, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your information.

4.5 Aggregated and De-Identified Data

We may share aggregated or de-identified information that cannot reasonably be used to identify you for any purpose, including research, marketing, and analytics.

4.6 With Your Consent

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


5. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including:

Active Accounts:
We retain your information for as long as your account remains active.

Closed Accounts:
After account closure, we retain your information for five (5) years or as required by applicable law, whichever is longer. This retention period is necessary to:

Legal Requirements:
We may retain certain information for longer periods if required by law, including financial transaction records, identity verification records, and responsible gaming records.

Aggregated Data:
We may retain aggregated, de-identified data indefinitely for analytics and research purposes.


6. COOKIES AND TRACKING TECHNOLOGIES

6.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help websites remember your preferences and understand how you use the site.

6.2 Types of Cookies We Use

Essential Cookies:
These cookies are necessary for the Platform to function properly. They enable core functionality such as account authentication, session management, and security features. You cannot opt out of essential cookies.

Analytics Cookies:
We use Google Analytics to collect information about how users interact with the Platform. This helps us understand usage patterns and improve our Services. Google Analytics uses cookies to collect anonymous usage data.

Advertising Cookies:
We may use advertising cookies and tracking pixels to measure the effectiveness of our marketing campaigns and to deliver relevant advertisements. These cookies may track your browsing activity across different websites.

6.3 Email Tracking

Our marketing emails may contain tracking pixels (small, invisible images) that tell us whether you have opened an email and which links you have clicked. This helps us measure the effectiveness of our email campaigns and tailor future communications.

6.4 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can typically:

Please note that disabling certain cookies may affect the functionality of the Platform.

Google Analytics Opt-Out:
You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout.

6.5 Do Not Track Signals

Some browsers include a “Do Not Track” (DNT) feature that signals to websites that you do not want your online activity tracked. There is currently no universally accepted standard for how to respond to DNT signals. At this time, the Platform does not respond to DNT signals.


7. DATA SECURITY

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

While we strive to protect your information, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee the absolute security of your information.

If we become aware of a security breach that affects your personal information, we will notify you in accordance with applicable law.


8. YOUR RIGHTS AND CHOICES

8.1 Account Information

You may access, update, or correct your account information at any time by logging into your account settings or by contacting us at privacy@joltryfantasy.com.

8.2 Marketing Communications

Opting In:
You may opt in to receive marketing communications from us during registration or at any time through your account settings.

Opting Out:
You may opt out of marketing communications at any time by:

Please note that even if you opt out of marketing communications, we will still send you transactional and service-related communications (such as contest results, account alerts, and policy updates).

8.3 Location Information

You may disable location services on your mobile device. However, precise location verification is required to participate in paid contests. If you disable location services, you may not be able to enter contests.

8.4 Account Deletion

You may request deletion of your account by contacting us at privacy@joltryfantasy.com. Please note that:


9. STATE-SPECIFIC PRIVACY RIGHTS

9.1 California Residents (CCPA/CPRA)

If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

Right to Know:
You have the right to request information about the categories and specific pieces of personal information we have collected about you, the sources of that information, the purposes for collecting it, and the categories of third parties with whom we share it.

Right to Delete:
You have the right to request deletion of your personal information, subject to certain exceptions.

Right to Correct:
You have the right to request correction of inaccurate personal information.

Right to Opt-Out of Sale/Sharing:
You have the right to opt out of the sale or sharing of your personal information. Joltry Sports does not sell your personal information.

Right to Non-Discrimination:
We will not discriminate against you for exercising your privacy rights.

Submitting Requests:
To exercise your rights, contact us at privacy@joltryfantasy.com or call 781-628-9912. We will verify your identity before processing your request.

Authorized Agents:
You may designate an authorized agent to make requests on your behalf. We may require verification that you authorized the agent.

Categories of Information:
In the preceding 12 months, we have collected the following categories of personal information:

Category Examples Collected
Identifiers Name, email, phone, address, IP address Yes
Personal Information (Cal. Civ. Code § 1798.80) Name, address, phone, bank account info Yes
Protected Classifications Age, date of birth Yes
Commercial Information Transaction history, contest history Yes
Biometric Information Facial geometry (for ID verification) Yes
Internet/Network Activity Browsing history, search history, interactions Yes
Geolocation Data Precise location Yes
Sensory Data Photographs (selfie for verification) Yes
Professional/Employment Information Not collected No
Education Information Not collected No
Inferences Preferences, characteristics Yes
Sensitive Personal Information SSN (last 4 digits), precise geolocation, biometric data Yes

9.2 Virginia Residents (VCDPA)

If you are a Virginia resident, you have the right to access, correct, delete, and obtain a copy of your personal data, and to opt out of targeted advertising and profiling. Contact us at privacy@joltryfantasy.com to exercise these rights.

9.3 Colorado Residents (CPA)

If you are a Colorado resident, you have similar rights to access, correct, delete, and obtain a portable copy of your personal data, and to opt out of targeted advertising, sale of personal data, and profiling. Contact us at privacy@joltryfantasy.com to exercise these rights.

9.4 Connecticut Residents (CTDPA)

If you are a Connecticut resident, you have the right to access, correct, delete, and obtain a copy of your personal data, and to opt out of targeted advertising, sale of personal data, and profiling. Contact us at privacy@joltryfantasy.com to exercise these rights.

9.5 Other States

Privacy laws are evolving. If you are a resident of a state with privacy legislation that provides you with specific rights regarding your personal information, please contact us at privacy@joltryfantasy.com to exercise those rights.


10. CHILDREN’S PRIVACY

The Platform is not intended for use by anyone under the age of eighteen (18), or the higher minimum age required in their jurisdiction. We do not knowingly collect personal information from children under 13 years of age in compliance with the Children’s Online Privacy Protection Act (COPPA).

If we learn that we have collected personal information from a child under 13, we will promptly delete that information. If you believe we have collected information from a child under 13, please contact us immediately at privacy@joltryfantasy.com.


11. BIOMETRIC DATA

11.1 Collection of Biometric Data

As part of our identity verification process, we collect biometric information in the form of facial geometry extracted from the selfie photograph you provide. This biometric data is used solely to verify that you are the person depicted in your government-issued identification document.

11.2 Purpose and Use

We collect biometric data exclusively for identity verification and fraud prevention purposes. We do not use biometric data for any other purpose, including marketing or profiling.

11.3 Storage and Retention

Biometric data is processed by our third-party identity verification provider. We retain verification results but do not store raw biometric data or facial geometry templates after the verification process is complete. Our identity verification provider’s retention and security practices are governed by their privacy policy and our data processing agreement.

11.4 Disclosure

We do not sell, lease, trade, or otherwise profit from your biometric data. Biometric data is shared only with our identity verification service provider for the purpose of verifying your identity.

11.5 Illinois Residents (BIPA)

If you are an Illinois resident, the Illinois Biometric Information Privacy Act (BIPA) provides you with specific rights regarding biometric data. By submitting a selfie for identity verification, you consent to the collection and use of your biometric information as described in this section. You may withdraw your consent at any time by contacting us, though this may affect your ability to use the Platform.

11.6 Texas Residents

If you are a Texas resident, you have rights under the Texas Capture or Use of Biometric Identifier Act. We will not capture your biometric identifier without your consent and will not sell, lease, or otherwise disclose your biometric identifier without your consent.


12. THIRD-PARTY LINKS AND SERVICES

The Platform may contain links to third-party websites, applications, or services that are not operated by us. This Privacy Policy does not apply to third-party services. We encourage you to review the privacy policies of any third-party services you access.

We are not responsible for the privacy practices or content of third-party services.


13. INTERNATIONAL USERS

The Platform is intended solely for users located in the United States. We do not knowingly collect information from or provide services to individuals located outside the United States.

If you access the Platform from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those of your country.


14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will:

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.


15. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Joltry Sports Inc.

Attn: Privacy Officer

306 Winthrop St. PMB #211
Taunton, MA 02780

Phone: 781-628-9912

Email: privacy@joltryfantasy.com

For general inquiries: support@joltryfantasy.com


BY USING THE JOLTRY SPORTS PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY.


© 2025 Joltry Sports Inc. All rights reserved.