Privacy Policy

We may revise this Privacy Policy at any time. You should review it periodically to stay informed. For material changes, we will provide notice as required by law, such as by email or in-app notification. For non-material changes, we will post the updated Privacy Policy on the Site with a new Effective Date. Your continued use of the Services after an update takes effect constitutes your acceptance of the revised Privacy Policy.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, as defined under applicable privacy law. Personal Information does not include de-identified, aggregated, or publicly available information. We collect Personal Information in three ways: directly from you, automatically when you use the Services, and from third parties.

Information We Collect Directly From You

You may provide Personal Information directly when you create an account, enter contests, make deposits or withdrawals, verify your identity, request information, or communicate with us. This may include:

• Identifiers and account information: real name, username, password, date of birth, email address, postal/mailing address, and telephone number.

• Identity verification (KYC) information: to verify your identity, age, and eligibility and to meet our legal obligations, we collect government-issued identification information, which may include your Social Security number and driver’s license or other government ID number. This information is collected and verified through our KYC provider, Plaid.

• Financial information: payment card, bank account, and related financial account information used to fund deposits, contest entries, withdrawals, and payouts, collected and processed through our third-party payment processor.

• Communications and content: the contents of messages, chats (including Bracket Chat), survey responses, feedback, and other information you submit through the Services or to our support team.

• AI Assist inputs: questions, prompts, and other information you provide when using our AI Assist features.

Information We Collect Automatically

When you use the Services, we and our service providers may automatically collect data to operate, secure, and improve the Services and to support analytics, including:

• Commercial information: products or services obtained, contests considered or entered, and related activity.

• Internet or other electronic network activity: browser and device information, operating system, unique device identifiers, browsing actions and patterns, clickstream, search activity, contest history, interactions with the Services, IP address, and information collected through cookies and similar technologies.

• Geolocation: IP-based location and precise (GPS) location. See “Real-Time Location” below.

Information We Receive From Third Parties

We may receive Personal Information or de-identified data about you from affiliates, business partners, service providers, and publicly available sources, obtained online or offline, and may combine it with information we already have. Sources include our service providers (including Plaid for identity verification and SOAP Payments for geolocation), our sports data and content providers (SportsDataIO and FantasyPros), advertising and analytics partners, and social media platforms (for example, Instagram, X/Twitter, or YouTube) when you interact with us there, subject to those platforms’ own privacy policies.

Cookies and Similar Technologies

Cookies. Cookies are small data files stored in your browser or on your device that help us recognize you, remember preferences, authenticate logins, measure and improve the Services, and collect aggregate statistics. You can disable cookies through your browser settings, though some features may not function properly. On mobile devices, you can limit ad tracking through your device settings (for example, App Tracking Transparency on iOS or Ads Personalization controls on Android).

Log files and web beacons. Our Site and emails may use web beacons (also called clear GIFs or pixel tags) to count visitors, understand whether an email was opened, and verify system integrity. Log files may include IP addresses, browser type, domain names, access times, and general location.

Heat mapping and session recording. We may use tools that record how users interact with the Services (such as mouse movements, clicks, and taps) to analyze and improve the experience. Some tools may record sessions for later playback.

Real-time location. The Services collect real-time device location. Disabling location will impair the Services, including your ability to deposit and enter contests, because we must confirm you are in a permitted jurisdiction.

Google Analytics. We may use Google Analytics to understand traffic and usage and to support personalization. For details, see Google’s privacy policies. You can opt out using Google’s opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.

We may disclose Personal Information to the following categories of recipients:

Service Providers and Vendors

• Plaid. We use Plaid Inc. (“Plaid”) to verify your identity and support our know-your-customer (KYC) and eligibility requirements. Your use of Plaid-enabled features is subject to Plaid’s end user privacy policy, which is incorporated by reference and which we encourage you to review.

• SOAP Payments (geolocation). We use SOAP Payments to verify your device location, including at the point of contest entry, so we can confirm you are in a jurisdiction where our contests are permitted. Your use of this feature is subject to SOAP’s privacy policy, which is incorporated by reference.

• Payment processing. We use a third-party payment processor to process deposits, contest entries, withdrawals, and payouts. Your payment information is handled subject to that processor’s privacy policy.

• Other providers. We also work with providers of cloud hosting, sports data and content (including SportsDataIO and FantasyPros), analytics, communications, and customer support. These providers may use Personal Information only as needed to perform services for us.

Companies Involved in Advertising

We may work with advertising and analytics partners that use cookies and similar technologies to measure and deliver advertising, including targeted advertising, across platforms. This may include advertising features offered by social platforms such as Meta and X/Twitter. Depending on your state, this activity may be considered a “sale” or “sharing” of Personal Information; see Sections 9 and 12 for your choices.

Business Partners

We may collaborate with other companies to offer, promote, or improve products or services, and may share Personal Information as reasonably necessary for those arrangements.

Other Situations

• Mergers, sales, or change of control: Personal Information may be transferred as part of a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets.

• Affiliates: We may share Personal Information with our corporate affiliates.

• Legal compliance and protection: We may disclose information when we believe it is necessary to comply with law or legal process, respond to lawful requests (including from gaming regulators and law enforcement), enforce our Terms, address fraud or security issues, or protect the rights, property, or safety of Shotgun Fantasy, our users, or others.

• Authorized representatives: Individuals you authorize to manage your account may access your Personal Information.

• With your consent or at your direction.

We do not sell your Personal Information for money to unaffiliated third parties except as described in this Privacy Policy or with your permission. We may use and disclose de-identified or aggregated information without restriction.

The Services may link to third-party websites, services, or advertisements that we do not control and that are not affiliated with us. We are not responsible for their privacy practices or content, and this Privacy Policy does not apply to information collected by them. We encourage you to review the privacy policies of any third party before providing your information.

The Services include public and social features, such as Bracket Chat and private contests (“Public Activities”), where you can interact with other participants. Information you share in these spaces — including your username and the content of your messages — may be visible to other users or the public and may be copied, stored, or re-shared by others. This Privacy Policy does not restrict how others use information you make available in Public Activities. Please use caution and avoid sharing sensitive Personal Information in these spaces.

Identity verification through Plaid. Shotgun Fantasy uses Plaid to verify your identity and gather related information for KYC and eligibility purposes. By using the Services, you grant Shotgun Fantasy the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution or identity source, and you agree that your information may be transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy.

We maintain reasonable administrative, technical, and physical safeguards designed to protect Personal Information against loss, theft, and unauthorized access, use, alteration, or disclosure, and we require our service providers to maintain appropriate protections. However, no method of internet transmission or electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your password confidential and for activity under your account, and for using caution in Public Activities.

We retain Personal Information only as long as necessary to provide the Services and for legitimate business or legal purposes, including compliance with our legal obligations, dispute resolution, and enforcement of our agreements. Retention criteria include the duration of our relationship with you (for example, while you have an active account), our legal obligations (such as KYC, anti-money-laundering, tax, and gaming recordkeeping requirements), and our legal position (for example, statutes of limitations, litigation, or regulatory investigations). Because of the rules that apply to real-money contests, we may be required to retain certain records even after you close your account.

The Services are available only in the United States, and Personal Information is stored and processed in the United States. If you access the Services from outside the United States, you consent to the transfer and processing of your Personal Information in the United States, which may have different privacy laws than your location.

You have choices about your information, though withholding information may limit the functionality available to you.

Account profile. You may review or update your Personal Information through your account settings or by contacting us to access, correct, or delete it. Deletion requests will deactivate your account as required by law, but we may retain information where legally required (for example, for KYC, tax, or responsible-gaming purposes). Contributions to Public Activities may remain in cached or archived pages or be copied by others.

Advertisements. Ads on or about the Services may use cookies and similar technologies from advertising partners to deliver targeted ads. This Privacy Policy does not cover advertisers’ own use of cookies. We may use your interactions to predict interests for interest-based advertising.

Do-Not-Track and Global Privacy Control. We do not currently respond to browser “Do Not Track” signals, but where required by law we honor recognized opt-out preference signals such as the Global Privacy Control (GPC), processing them as applicable (for example, as “do not sell/share” or targeted-advertising opt-outs).

The Services are intended only for individuals who are at least 18 years old (or the age of majority in their state, if higher). We do not knowingly collect Personal Information from anyone under 18. If you are under 18, do not use the Services or provide us with any information. If you believe we have collected information from someone under 18, please contact us and we will take appropriate steps to delete it.

Shotgun Fantasy is committed to responsible gaming. We provide tools that help you manage your play, which may include setting deposit, entry, or spending limits, taking a temporary cooling-off period, or self-excluding from the Services. To make these tools available and to enforce the limits and exclusions you request — as well as any we are required to apply — we collect and process related Personal Information, such as your account activity, the limits you set, and your self-exclusion status. We may share this information with our service providers and, where required, with regulators, and we may retain responsible-gaming records, including self-exclusion records, for as long as required by applicable law, even after you close your account. If you self-exclude, we may use your information to help prevent you from opening a new account or entering contests during the exclusion period.

Depending on your state of residence (for example, Colorado, Connecticut, Virginia, Texas, or Florida, as those laws apply), you may have some or all of the following rights regarding your Personal Information, subject to applicable law:

• Confirm processing, access, and obtain a copy of your Personal Information;

• Correct inaccurate or incomplete Personal Information;

• Delete your Personal Information;

• Data portability — request transfer of your Personal Information to another organization;

• Opt out of targeted advertising and the “sale” or “sharing” of your Personal Information;

• Limit the use or disclosure of certain sensitive Personal Information, and opt out of certain automated decision-making, where applicable;

• Not be subject to unlawful discrimination for exercising your rights;

• Appeal a decision we make about your request; and

• Lodge a complaint with your state attorney general or supervisory authority.

To exercise these rights, see Section 13.

To exercise any of the rights described above, contact us using the information in Section 14. For your protection, we verify your identity before responding, which may include confirming information we already have (such as name, email address, date of birth, phone number, or address) and may require additional information. You can generally expect: confirmation of receipt within 10 days; and a substantive response within 45 days (which may be extended by an additional 45 days with notice), consistent with applicable law. If we deny a request, we will explain why, where required.

Authorized representatives. You may designate an authorized agent to submit requests on your behalf. We may require proof of the agent’s authorization, verify your identity directly, and/or ask you to confirm that you authorized the request.

If you have questions about this Privacy Policy or wish to exercise your privacy rights, contact us at:

Shotgun Fantasy Sports, Inc.

Attn: Privacy

251 Little Falls Drive

Wilmington, DE 19808

Email: [email protected]

Customer Support chat: available in the App