Date of Last Revision: 4 April 2022

Our business name is HOFr Inc. (“HOFr”, “Company”, “we”, “us” and/or “our”). We are the owner of HOFr Payment Services LLC, the website www.hofr.io as well as the HOFr mobile application. Our services are designed to offer users (collectively, “Users,” “you,” or “your”) the opportunity to participate in fantasy contests (“Contest(s)”), or other content, products, services, and promotion (collectively “the Services”). The Services are provided to you through our mobile application (“App”).

HOFr takes your privacy seriously and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store and protect your personal data, and informs you about your rights in regards to the processing of your personal data.

By using our Services, you acknowledge reading and consenting to the terms of this Privacy Policy. If you do not agree to the data collection, use, and sharing practices described in this Privacy Policy, you may not use our website or App. AS MORE CLEARLY DEFINED HEREIN, WE WILL NEVER KNOWINGLY SELL OR ASSIGN YOUR PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE AND/OR APPROVAL. This Privacy Policy shall be read in conjunction with our Terms of Service available here.

Modifications to the Privacy Policy

We reserve the right to amend, modify or revise portions of this Privacy Policy at any time. If we do so, we will post the changes on this page and will indicate at the top of this page the date these terms were last revised. Any such changes will take effect from the moment they appear on our website and App. In the event we make material changes, we will notify you either through the Services user interface, in an email notification or through other reasonable means. Your continued use of the Services after the date any such changes become effective constitutes your acceptance of the new Privacy Policy.

INFORMATION WE COLLECT

When you interact with our App, we collect information that, alone or in combination with other information, could be used to identify you (“Personal Data”). We only process your personal data to the extent that it is necessary and appropriate to the purposes for which it is collected. We make our best efforts to ensure that your personal data is secure, accurate and, where necessary, updated with regard to the purposes of the processing, taking all reasonable steps to delete, anonymize, or correct it in case of inaccuracy. It is your responsibility to update any and all personal identifiable information provided for use of our Services.

Personal Data You Provide to Us

You may agree to provide some information to create an account and use our Services. HOFr may process your personal data as follows, in order to fulfill our obligations under our Terms of Services located here, and comply with our legal duties.

1. Account Information

   • In order to provide you with our Services, we need to process the information you may decide to share with us, such as your first name, last name, birthdate, location, email address, Face ID, phone number, username, and the country and state in which you reside.
   • When you deposit or withdraw funds from your account, we may collect your name, address, location, email address, phone number, credit or debit card information and other billing information, government identification number(s), tax documents to complete the transactions, provide you with the Services, and comply with relevant laws.
   • If you choose to log in, access or otherwise connect to our Services through a social networking service, such as Facebook, we may collect your user ID, email address, profile photo associated with that social networking service as well as any information you make public using that social networking service or which the social networking service allows us to access. We may also collect information you have authorized the social networking service to share with us on your behalf. This information allows us to verify information that you have provided through the use of our Services.

2. Location Information

   When enabled by you, we collect location information provided by your device. We may also obtain location information you provide in your profile or from your Internet Protocol (IP) address. With your consent, where required by the applicable law, we may also determine location by using other data from your device, such as precise location information from GPS, information about wireless networks or cell towers near your mobile device. This information is used to verify your eligibility to enter our Contests, to complete deposits and/or withdrawals, to comply with relevant laws, and for money-laundering and fraud prevention purposes.

3. Interactions With The Services

   • We collect the information you provide when you interact with the Services, such as when responding to a prompt or visiting the App. We also collect the metadata associated with those interactions (such as, but not limited to, the date and frequency).
   • The profile photo you may upload and username you choose will be visible to other users in the Contest(s) you participate in.
   • If you contact us via email, we may collect your name and email address, as well as any other content provided in the email, in order to send you a reply, provide you support, improve our Services, comply with our legal obligations, and address any complaint.
   • If you agree to participate in one of our surveys, we may collect (but not store) additional data about your profile, activity, usage, and preferences so that we can improve our Services to you.
   • We may collect information about you from third parties, such as marketing partners, identity verification service providers, anti-money laundering and anti-fraud services, and other service providers.

Information We Receive From Your Use of Our Services

When you use our Services, we may request your permission in order to track certain data about your visits to and usage of our Services to improve, customize, and optimize our Services, and comply with our legal obligations. The information (“log data'') is generated automatically by the App and automatically logged in our systems.

We may use this information to analyze trends, gather demographic information about our user base, promote our Services, perform research, provide technical and customer support, inform our product development efforts, comply with our legal obligations, address disputes, and prevent our Services from being used to commit harmful or unlawful activities, including fraud and money laundering. Some of this data may also be collected so that when you use the Services again, we will be able to recognize you and optimize your experience accordingly.

1. Log data

   The log data includes your Internet Protocol (“IP”) address, browser type and settings, the date and time of your request, geolocation, and how you interacted with the Services.

2. Device information

   The Device information includes the type of device you are using, operating system, settings, unique device identifiers, network information and other device-specific information. Information collected may depend on the type of device you use and its settings.

3. Usage Information

   We collect information about how you use our Services, such as the types of content that you view or engage with, the features you use, the actions you take, your money movements (deposits and withdrawals), your winnings, frequency and duration of your activities.

HOW WE USE INFORMATION