Privacy Policy

Last updated: November 15th, 2024

OUR COMMITMENT TO PRIVACY
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Fanstake, Inc. (“Fanstake”, “we”, “our”, or “us”), know that you (“User”, “you”, or “your”) care about how your personal information is used and shared, and we take your privacy seriously. Our primary goal is to provide you with exceptional Services (as defined herein below) and we understand that you may have questions or concerns regarding your personal information and how it will be used. To make this privacy policy (“Privacy Policy”) easy to find, we make it available at https://www.fanstake.com (“Website”) or through our mobile application, the extent that we may offer a mobile application (“App”, together with the Website, “Platform”). You may also email us at privacy@fanstake.com with any privacy-related questions you have. For purposes of this Privacy Policy, our services include any access, use, interaction, or engagement you have with us via our Platform, online features, dashboards, or customer service channels (“Services”). By using our Services, you acknowledge that you have read and understand this Privacy Policy.
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Applicability of Privacy Policy
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This Privacy Policy applies to all personal information (as defined herein below) we collect when you use our Services or contact us. When you are no longer a User, we may continue to share your personal information as described in this Privacy Policy.
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Throughout this policy, we use the term "personal information" to describe information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household. Categories of personal information include, but are not limited to, the following:

Identifiers: name, alias, address, online identifier, Internet Protocol address, email address, account name, Social Security number, Driver’s license number, passport number.
Customer records: name, signature, Social Security number, physical characteristics or description, address, telephone number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, financial and transactional information such as your money transfers, payments, deposits and the source/destination of funds for each, Fanstake handle and/or username and password (collectively, “Fanstake Login Credentials”), name and contact information relating to whom you send or from whom you request or receive money or with whom you otherwise choose to transact when using the Services, any other financial information (i.e., medical information, health insurance information.
Characteristics of protected classifications under state or federal law: age (over 40), AIDS/HIV-positive status, ancestry, citizenship status, disability, gender identity or expression, genetic information or conditions, marital status, medical condition, military or veteran status, national origin, political affiliations or activities, pregnancy, race, religion, sex (including pregnancy, childbirth, and related medical conditions), sexual orientation.
Commercial information: records of personal property, products or services purchased, obtained, or considered or other purchasing or consuming histories or tendencies.
Biometric information: imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
Internet or other network activity information: browsing history, search history, information regarding a consumer’s interaction with an internet website application, or advertisement, or other similar information.
Geolocation data: any data that is derived from a device and that is used or intended to be used to locate a consumer within a geographic area
Audio, electronic, visual, thermal, olfactory, or similar information (collectively referred to as “Sensory information”), as described in the category name.
Professional or employment-related information, as described in the category name.
Education information: information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g; 34 C.F.R. Part 99).
Sensitive personal information, Social Security number, driver’s license number, state identification card number, passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation (meaning any geolocation data that can be used to locate a consumer within a radius of 1,850 feet), racial or ethnic origin, religious or philosophical beliefs, union membership, contents of a consumer’s mail, email, and text messages unless the business collecting or using the data is the intended recipient of the communication, genetic data, biometric information for the purpose of uniquely identifying a consumer, personal information collected and analyzed concerning a consumer’s health, personal information collected and analyzed concerning a consumer’s sex life or sexual orientation, when collected or used for the purposes of inferring characteristics about a consumer.
Inferences drawn from any of the information in any other category to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Personal information does not include deidentified or aggregate personal information or information that is lawfully made available from federal, state, or local government records.

Personal information is not considered to have been disclosed when you instruct a business to transfer your personal information from one business to another in the context of switching services.

Personal Data We Do Collect

Personal data you provide: We collect personal information when you apply for a User account at Fanstake (“Account”). The personal information collected during these interactions may include, but is not limited to, name, date of birth, physical address, email address, phone number, bank account number, biometric data, your photograph, a photograph of your passport or driver’s license or national identity document, any personal information that you provide. We may need to collect additional personal information, such as your street address, your Social Security Number or zip code to fulfill our legal obligations related to providing the Services to you. In addition, we may collect your location information. Additionally, when you use our Services, we will collect information about your transactions and activity, including financial institution and bank account or credit card information.

When you contact customer support or communicate with us in any other way, we will collect whatever information you volunteer, in addition to your name and email address.
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You are responsible for the accuracy of the personal information you provide to us and you will be responsible for the consequences of providing false or inaccurate information.
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Personal Data We Receive Automatically from Your Use of the Service: When you visit, use and interact with the Service, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Services (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:

Log data: Information that your browser automatically sends whenever you visit the Platform (“Log Data”). Log Data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Service; and
Cookies: Please see the “Cookies” section below to learn more about how we use cookies.
Pixel Tags/Web Beacons: A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement on the Services. The use of a pixel tag allows us to record, for example, that a User has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded; and
Biometric information: imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
Device information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings; and
Usage Information: We collect information about how you use the Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities (collectively, “Technologies”).

Cookies: We use cookies to operate and administer our Website, gather usage data on our Website and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.
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Our use of the Technologies fall into the following general categories:

Operationally Necessary. These Technologies allow you to access and use the Platform and the Services and are required so that we may identify irregular Platform behavior, prevent fraudulent activity, and improve security.
Performance Related. We may use Technologies to assess the performance of the Services, including as part of our analytic practice to help us understand how Users interact with the Services (please see the “Analytics” section below to learn more about how we use analytics).
Functionality Related. We may use Technologies to allow us to offer Users enhanced functionality when accessing the Services. This may include identifying you when you sign into your Account or keeping track of your specified preferences, interests, or past items viewed.
Advertising or Target Related. We may use first party or third-party Technologies to deliver content, including ads and direct mail relevant to a User’s interests, the Service, or other third-party digital properties.

Analytics: We may use Technologies and other third-party tools to process analytics information about the Services. These Technologies allow us to better understand how the Services are used to continually improve and personalize the Services. Below, we list some of the analytics service providers we use, including links where you can find more information about the analytics services and where you can opt out of the analytic service’s collection (when applicable).

PostHog Web Analytics. We use PostHog Web Analytics, a web analytics service provided by PostHog, Inc. (“PostHog”) for Users who are at least 18 years of age. PostHog Web Analytics uses cookies to help us analyze how Users use the Website and enhance your experience when you use the Website. For more information on how PostHog uses this data, go to https://posthog.com/privacy.

Information We Get From Third Parties: We may collect personal information about you from our affiliates, Service Providers (as defined herein below), Vendors (as defined herein below) and third parties as permitted by law. For example, we may collect information from third-party verification services, credit bureaus, financial institutions, mailing list providers, and publicly available sources to verify your identity. We may also collect information about you from third parties in connection with any identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law.

When you use the App, we may collect information from your wireless operator such as your mobile number, name, address, email, unique mobile device identifier and other subscriber details. For fraud protection purposes only, (i) we collect your battery usage, device identifier, device storage, MAC address, and SIM information; (ii) we also collect enough information to determine if you are trying to fake your current location by using a VPN, VPN apps with location spoofing, or other related tools.

Online Tracking and Do Not Track Signals: We, our Service Providers (as hereinafter defined), and Vendors (as hereinafter defined) may use cookies or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Website. Our Website currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

Your Choices. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off.

Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Website and you may not be able to benefit from the full functionality of the Website.Advertising networks may collect personal information through the use of cookies.

Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there.
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If you access the Website on your mobile device, you may not be able to control tracking technologies through the settings.

How we use personal data

We may use personal information for the following purposes:

To enable you to access the Platform by using your Fanstake Login Credentials;
To help you access and use the Services and manage your Account;
To respond to your inquiries, comments, feedback or questions;
To send administrative information to you, for example, monthly Account statements, information regarding the Service, and changes to our Terms, conditions, and policies;
To analyze how you interact with the Services;
To process your financial information and other payment information;
To maintain and improve the content and functionality of the Services (please see the “Cookies” section above to learn how we use cookies);
To develop new products and services;
To prevent fraud, criminal activity, or misuses of the Services, and to ensure the security of our IT systems, architecture and networks; and
To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.

Aggregated Information. We may aggregate personal information and use the aggregated information to analyze the effectiveness of the Service, to improve and add features to the Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of Users of the Services and share or sell anonymized aggregated information like general User statistics with prospective business partners. We may collect aggregated information through features of the software that supports the Service, through cookies, and through other means described in this Privacy Policy.
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Marketing. We may contact you to tell you about Services we believe will be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email or text message we send you. You can also control the marketing emails and/or text messages you receive by updating your settings through your Account. In addition, if at any time you do not wish to receive future marketing communications, please contact us at privacy@fanstake.com. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding our Platform and the Services and to respond to your requests.

Sharing and disclosure of personal data

In certain circumstances we may share your personal information with third-parties without further notice to you, unless required by the law, as set forth below:

Business Partners: As set forth above in Section 2 under “Aggregated Information”.
Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain Services and functions, including payment processing, we may share personal information with vendors (“Vendors”) and service providers (“Service Providers”), including providers of hosting services, cloud services and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, financial service providers (including Payment Processors, banks, and API services), customer relationship management and customer support services, and web analytics services (for more details on the third parties that place cookies through the Website, please see the “Cookies” section above). Pursuant to our instructions, these parties will access, process or store personal information in the course of performing their duties to us. We take commercially reasonable steps to ensure our Vendors and Service Providers adhere to the security standards we apply to your personal information.
Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of the Services to another provider, your personal information and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.
Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of Users of the Service, or the public, or (v) protect against legal liability.
Affiliates: We may share personal information with our affiliates, meaning an entity that controls, is controlled by, or is under common control with either Sig Sauer or Program Manager. Our affiliates may use the personal information we share in a manner consistent with this Privacy Policy.

Data Retention

We keep personal information for as long as reasonably necessary and proportionate to: (1) achieve the purposes for which the personal information was collected or processed, (2) provide Users the Service, (3) resolve disputes, (4) establish legal defenses, (4) conduct audits, (5) pursue legitimate business purposes, (6) enforce our agreements, and (7) comply with applicable laws.

Update your information

Please log in to your Account if you need to change or correct your personal information. Additionally, you can email us at privacy@fanstake.com to request that we correct any inaccurate personal information about you.

Children

The Services are not directed to children who are under the age of 16. We do not knowingly collect personal information from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided personal information to us through the Service, please contact us at privacy@fanstake.com and we will endeavor to delete that information from our databases.

Software Development Kits

We may use third party applications programming interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of the Service. APIs and SDKs may allow third parties including advertising partners to collect your personal information to provide content that is more relevant to you. For more information about our use of APIs and SDKs, please contact as via email at privacy@fanstake.com.

Security

You use the Services at your own risk. We implement reasonable technical, administrative, and organizational measures to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Services or e-mail. Please keep this in mind when disclosing any personal information to us via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service or third-party websites.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

Your choices

In certain circumstances providing personal information is optional. However, if you choose not to provide personal information that is needed to use some features of the Services, you may be unable to use those features.

Changes to the Privacy Policy

The Service, and our business may change from time to time. As a result, we may change this Privacy Policy at any time. When we do, we will post an updated version on this page as well as our App, unless another type of notice is required by the applicable law. By continuing to use the Services or providing us with personal information after we have posted an updated Privacy Policy, or notified you if applicable, you consent to the revised Privacy Policy and practices described in it.

California-specific Consumer Privacy Protections

We currently do not meet the threshold requirements obligating our compliance with the California Consumer Privacy Act of 2018, as revised by the California Privacy Rights Act of 2020, and the associated regulations (“CCPA/CPRA”) and other California Laws. If we do so in the future, we will describe the privacy rights to which you would be entitled as a consumer under the CCPA/CPRA in this Privacy Policy.

Contact us

If you have any questions or concerns about our Privacy Policy or information practices, please feel free to contact us via email at privacy@fanstake.com.