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Privacy Policy

Last Updated: Feb 23, 2026

1. Introduction and Scope

1.1 Purpose of This Policy

NX1 Connect ('we,' 'our,' 'us,' 'Company,' or 'NX1 Connect') is committed to protecting your privacy and handling your personal information responsibly and transparently. This Privacy Policy ('Policy,' 'Privacy Policy,' or 'Policy') explains in detail how we collect, use, disclose, transfer, store, safeguard, and otherwise process your information when you access, download, install, register with, or use our mobile application, website, or any related services (collectively, the 'App,' 'Service,' 'Platform,' or 'Services').

1.2 Your Consent

By accessing, downloading, installing, registering with, or using the App, you acknowledge that you have read, understood, and consent to the data practices described in this Policy. If you do not agree with this Policy, please do not use the App and must immediately delete your account, if any.

1.3 Applicability

This Policy applies to all users of the App, including but not limited to: (a) visitors who browse the App without creating an account; (b) registered users who create accounts; (c) subscribers who purchase premium features; (d) athletes, businesses, administrators, and other user types; and (e) any other individuals or entities that access or use the App.

1.4 Incorporation into Terms of Service

This Privacy Policy is incorporated into and forms part of our Terms of Service. By agreeing to the Terms of Service, you also agree to this Privacy Policy. In case of conflict between the Terms of Service and this Privacy Policy regarding privacy matters, this Privacy Policy shall govern.

1.5 Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other reasons. We will notify you of material changes as described in Section 16 of this Policy. Your continued use of the App after changes constitutes acceptance of the updated Policy.

2. Information We Collect - Comprehensive Overview

2.1 Information You Provide Directly to Us

We collect information that you provide directly to us when you interact with the App, including but not limited to when you:

  • Create an account, register, or sign up for the App
  • Complete, update, or modify your profile information
  • Post, upload, share, or distribute content (text, images, videos, and other media)
  • Communicate with other users through messaging, comments, or other communication features
  • Participate in educational courses, content, or learning activities
  • Use AI-powered features, chat, or automated assistance
  • Contact us for customer support, technical assistance, or inquiries
  • Subscribe to premium features or make purchases
  • Participate in surveys, contests, promotions, or other activities
  • Report content, users, or violations
  • Provide feedback, suggestions, or reviews

The information you provide may include, but is not limited to:

  • Personal identification information (full name, email address, username, phone number)
  • Profile information (sport, school, university, academic year, bio, interests, skills, achievements)
  • Location data (city, state, country, GPS coordinates, address)
  • Social media information (links, handles, follower counts, engagement metrics)
  • Media content (profile photos, images, videos, audio recordings)
  • Payment and billing information (processed securely through third-party providers)
  • Communications and correspondence (messages, emails, support tickets)
  • Educational information (course progress, completion, assessments, certificates)
  • NIL-related information (opportunities, contracts, transactions, income)
  • Verification information (identity documents, business credentials, certifications)

2.2 Information Automatically Collected

When you access or use the App, we automatically collect certain information about your device, usage patterns, and interactions, including but not limited to:

  • Device information (device type, model, manufacturer, operating system, version, unique device identifiers, device IDs, advertising identifiers)
  • Usage data (features used, time spent, pages viewed, screens accessed, interactions, clicks, taps, swipes, searches performed)
  • Location data (if you enable location services, including precise GPS coordinates, approximate location, IP-based location, network-based location)
  • Log data (IP address, access times, dates, timestamps, app crashes, error reports, performance metrics, diagnostic information)
  • Cookies and similar tracking technologies (cookies, web beacons, pixel tags, local storage, session storage)
  • Network information (connection type, mobile carrier, network operator, Wi-Fi information, signal strength)
  • App performance data (load times, response times, error rates, crash reports)
  • Interaction data (user interactions, engagement metrics, preferences, behavior patterns)
  • Technical data (browser type, language settings, time zone, screen resolution, display settings)

2.3 Information from Third-Party Sources

We may receive information about you from third-party services, platforms, and sources, including but not limited to:

  • Social media platforms (when you link your accounts, including profile information, posts, followers, engagement data)
  • Authentication services (Apple Sign In, Google Sign In, including name, email, and profile information)
  • Payment processors (transaction information, payment methods, billing addresses, purchase history)
  • Analytics providers (usage statistics, user behavior, engagement metrics, demographic information)
  • Public databases and directories (public records, business registrations, professional directories)
  • Data brokers and data providers (demographic data, interest data, marketing data, where permitted by law)
  • Educational institutions (verification data, enrollment information, athletic participation, where authorized)
  • Government sources (public records, regulatory filings, where publicly available)

2.4 Information Derived or Inferred

We may derive or infer information about you from the information we collect, including but not limited to:

  • Preferences, interests, and behavior patterns
  • Demographic information and characteristics
  • Risk scores, trust scores, or reputation metrics
  • Recommendations and personalized content preferences
  • NIL score calculations and market value estimates
  • Matching scores and compatibility metrics

3. How We Use Your Information - Detailed Purposes

3.1 Service Provision and Operation

We use the information we collect to provide, maintain, operate, and improve the App and its features, including but not limited to:

  • Creating, managing, and maintaining your account and profile
  • Authenticating your identity and authorizing access to the App
  • Processing transactions, payments, and subscriptions
  • Delivering content, features, and functionality
  • Providing customer support and responding to inquiries
  • Sending notifications, alerts, and communications
  • Personalizing your experience and providing recommendations
  • Facilitating connections and communications between users

3.2 NIL-Specific Features

We use your information to provide NIL-specific features and services, including:

  • Calculating and displaying NIL scores, analytics, and insights
  • Facilitating business-athlete matching and partnership opportunities
  • Providing market intelligence and trend analysis
  • Enabling location-based discovery and matching
  • Supporting contract and opportunity discovery

3.3 Educational Services

We use your information to provide educational content and services, including:

  • Delivering courses, content, and learning materials
  • Tracking your progress, completion, and achievements
  • Providing personalized learning recommendations
  • Issuing certificates or credentials
  • Facilitating educational discussions and forums

3.4 Communication and Engagement

We use your information to communicate with you and engage with you, including:

  • Sending you notifications, updates, and alerts
  • Responding to your inquiries and providing customer support
  • Sending you marketing communications (with your consent, where required)
  • Sending you service-related communications
  • Facilitating communications between you and other users

3.5 Safety, Security, and Compliance

We use your information to ensure safety, security, and compliance, including:

  • Detecting, preventing, and addressing fraud, abuse, and security issues
  • Investigating violations of our Terms of Service or applicable laws
  • Enforcing our Terms of Service and other agreements
  • Complying with legal obligations and regulatory requirements
  • Protecting the rights, property, and safety of NX1 Connect, our users, and others
  • Responding to legal processes, subpoenas, and government requests

3.6 Analytics, Research, and Improvement

We use your information for analytics, research, and improvement purposes, including:

  • Analyzing usage patterns, trends, and user behavior
  • Conducting research and development to improve our services
  • Testing new features, functionality, and improvements
  • Measuring the effectiveness of our services and features
  • Understanding user needs and preferences
  • Improving user experience and interface design

3.7 Legal Bases for Processing

We process your information based on the following legal bases, as applicable:

  • Performance of a contract: To provide the App services and fulfill our contractual obligations to you
  • Legitimate interests: To improve our services, ensure security, prevent fraud, and conduct business operations
  • Consent: For marketing communications, certain data uses, and where required by applicable law
  • Legal obligations: To comply with applicable laws, regulations, and legal processes
  • Vital interests: To protect the safety and security of users and others
  • Public interest: To comply with public health, safety, or other public interest requirements

4. Information Sharing and Disclosure - Comprehensive Disclosure

4.1 Public Information and Profile Visibility

Certain information is visible to other users of the App as part of the App's core functionality, including:

  • Your profile information (name, username, sport, school, bio, profile photo, verification status)
  • Your approximate location (if location services are enabled, including city and state)
  • Your NIL score and public analytics (as configured in your privacy settings)
  • Content you post publicly (posts, comments, shares, and other public content)
  • Your public activity and interactions (likes, comments, shares, and other public engagements)
  • Your connection status and network (mutual connections, followers, following)

You can control the visibility of some information through your privacy settings, but certain information must remain public for the App to function properly.

4.2 Sharing with Other Users

As part of the App's core functionality, we share your information with other users to enable:

  • Profile viewing, discovery, and browsing
  • Messaging, communication, and collaboration
  • Connection, networking, and relationship building
  • Location-based features and matching
  • Business-athlete matching and opportunity discovery
  • Social networking and community features

The extent of information sharing depends on your privacy settings and the nature of your interactions with other users.

4.3 Service Providers and Business Partners

We may share your information with third-party service providers, vendors, contractors, and business partners who assist us in operating the App and providing services, including but not limited to:

  • Cloud storage and hosting providers (Firebase, Google Cloud Platform, Amazon Web Services)
  • Database and data management services
  • Analytics and data processing services (Google Analytics, Firebase Analytics, and others)
  • Payment processors and billing services (Apple, Stripe, PayPal, and others)
  • Customer support and communication services
  • Marketing and advertising partners (with your consent, where required)
  • Email and notification services
  • Content delivery networks (CDNs) and performance optimization services
  • Security and fraud prevention services
  • Legal and compliance services

These service providers are contractually obligated to protect your information, use it only for the purposes we specify, and comply with applicable data protection laws. We require our service providers to implement appropriate technical and organizational security measures.

4.4 Legal Requirements and Law Enforcement

We may disclose your information when required by law or to:

  • Comply with legal processes, subpoenas, court orders, or government requests
  • Respond to law enforcement requests and investigations
  • Enforce our Terms of Service and other agreements
  • Protect the rights, property, or safety of NX1 Connect, our users, or others
  • Respond to legal claims or prevent illegal activity
  • Comply with applicable laws, regulations, and regulatory requirements
  • Respond to emergency situations or protect public safety

We may disclose information without notice to you if required by law or if we believe in good faith that disclosure is necessary to protect our rights, property, or safety, or that of our users or others.

4.5 Business Transfers and Corporate Transactions

In the event of a merger, acquisition, reorganization, bankruptcy, sale of assets, or other corporate transaction, your information may be transferred to the acquiring entity, successor entity, or other party to the transaction as part of the transaction. We will provide notice of such transfers as required by applicable law.

4.6 With Your Consent

We may share your information with third parties when you explicitly consent to such sharing, including when you: (a) authorize us to share information with specific third parties; (b) participate in features that require information sharing; or (c) opt in to information sharing for specific purposes.

4.7 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified data that cannot be used to identify you with third parties for research, analytics, marketing, or other purposes. This data may include statistical information, trends, patterns, and insights derived from user data.

4.8 We Do Not Sell Your Personal Information

We do not sell your personal information to third parties for their marketing or commercial purposes. We may share your information as described in this Policy, but we do not engage in the sale of personal information as that term is defined under applicable privacy laws, including the California Consumer Privacy Act ('CCPA').

5. Data Storage, Security, and Safeguards

5.1 Data Storage and Infrastructure

Your information is stored using industry-standard cloud services and infrastructure, including but not limited to Firebase (Google Cloud Platform) and other secure cloud providers. Data may be stored in data centers located in the United States and other countries, as described in Section 11 of this Policy.

5.2 Security Measures

We implement appropriate technical and organizational security measures to protect your information, including but not limited to:

  • Encryption of data in transit using industry-standard protocols (TLS/SSL)
  • Encryption of data at rest using industry-standard encryption algorithms
  • Access controls, authentication, and authorization mechanisms
  • Regular security assessments, audits, and penetration testing
  • Secure data centers with physical security controls
  • Network security measures, firewalls, and intrusion detection systems
  • Employee training and security awareness programs
  • Incident response procedures and breach notification protocols
  • Regular security updates and patch management
  • Data backup and disaster recovery procedures

5.3 Security Limitations

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security. You acknowledge that: (a) there are inherent security risks in transmitting information over the internet; (b) we cannot guarantee that your information will be completely secure; and (c) you use the App at your own risk regarding information security.

5.4 Your Security Responsibilities

You are responsible for maintaining the security of your account credentials, including your password and any other authentication information. You should: (a) use a strong, unique password; (b) not share your account credentials with others; (c) log out of shared or public devices; (d) notify us immediately of any security breaches; and (e) use two-factor authentication if available.

5.5 Data Breach Notification

In the event of a data breach that may affect your personal information, we will: (a) investigate the breach promptly; (b) notify affected users and relevant authorities as required by applicable law; (c) take appropriate steps to mitigate the breach and prevent further harm; and (d) provide information about steps you can take to protect yourself. We will notify you of any material data breach without undue delay and in accordance with applicable law.

6. Location Data and Geolocation Services

6.1 Location Data Collection

If you enable location services, we collect and use your location data, including: (a) precise GPS coordinates; (b) approximate location based on IP address or network information; (c) location history and patterns; and (d) location-based preferences and settings.

6.2 Use of Location Data

We use location data to: (a) display your location on the map feature; (b) help businesses find nearby athletes and vice versa; (c) provide location-based recommendations and matching; (d) improve our services, analytics, and user experience; and (e) provide location-based features and functionality.

6.3 Location Data Sharing

If you enable location sharing, your approximate location (city and state) may be visible to other users through the App's mapping and discovery features. You can control location sharing through your device settings and the App's privacy settings. Disabling location services may limit certain App features.

6.4 Location Data Accuracy

Location data may be approximate and may not be precise. We use both precise (GPS-based) and approximate (IP-based or network-based) location data. We are not responsible for the accuracy of location data or for how other users use location information.

7. Cookies, Tracking Technologies, and Analytics

7.1 Types of Tracking Technologies

We use cookies, web beacons, pixel tags, local storage, session storage, and similar tracking technologies ('Tracking Technologies') to: (a) remember your preferences and settings; (b) analyze how you use the App; (c) provide personalized content and advertising; (d) improve our services; (e) authenticate your identity; and (f) ensure security.

7.2 Third-Party Analytics and Tracking

We may use third-party analytics and tracking services, including but not limited to Google Analytics, Firebase Analytics, and other analytics providers. These services may use Tracking Technologies to collect information about your use of the App. You can control some Tracking Technologies through your device settings, but disabling Tracking Technologies may limit certain App features.

7.3 Do Not Track Signals

Some browsers and devices support 'Do Not Track' ('DNT') signals. We do not currently respond to DNT signals, but we respect your privacy choices as described in this Policy.

8. Children's Privacy and COPPA Compliance

8.1 Age Restrictions

The App is not intended for, and we do not knowingly collect personal information from, children under 13 years of age. If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information promptly in accordance with applicable law, including the Children's Online Privacy Protection Act ('COPPA').

8.2 Parental Rights

If you are a parent or guardian and believe your child under 13 has provided us with personal information, please contact us immediately. Parents and guardians have the right to: (a) review their child's personal information; (b) request deletion of their child's personal information; (c) refuse to allow further collection or use of their child's information; and (d) revoke consent previously given.

8.3 Minor Users (13-17)

Users between 13 and 18 years of age should have parental or guardian consent to use the App. We recommend that parents and guardians supervise their children's use of the App and review their children's privacy settings.

9. Your Rights and Choices - Comprehensive Rights

9.1 General Privacy Rights

Depending on your location and applicable law, you may have certain rights regarding your personal information, including:

  • Right to Access: Request access to your personal information and receive a copy of your data
  • Right to Rectification: Request correction of inaccurate or incomplete information
  • Right to Erasure: Request deletion of your personal information ('right to be forgotten')
  • Right to Restrict Processing: Request limitation of how we use your information
  • Right to Data Portability: Request a copy of your data in a portable, machine-readable format
  • Right to Object: Object to certain processing of your information
  • Right to Withdraw Consent: Withdraw consent where processing is based on consent
  • Right to Opt-Out: Opt out of certain data uses, including marketing communications

9.2 How to Exercise Your Rights

To exercise these rights, you can: (a) update your information directly through the App settings; (b) delete your account through the App settings; (c) adjust your privacy settings in the App; (d) contact us through the App's support features; or (e) send a written request to the contact information provided in the App.

9.3 Verification and Response

We will respond to your requests within a reasonable timeframe and in accordance with applicable law. We may require verification of your identity before processing certain requests to protect your privacy and security. We may charge a reasonable fee for excessive or repetitive requests, as permitted by applicable law.

9.4 Additional Privacy Controls

You can also control your privacy through: (a) device settings (location services, notifications, etc.); (b) App privacy settings (profile visibility, location sharing, etc.); (c) notification preferences; (d) marketing communication preferences; and (e) cookie and tracking preferences.

10. Data Retention and Deletion

10.1 Retention Periods

We retain your information for as long as: (a) your account is active or as needed to provide services; (b) necessary to comply with legal obligations, regulatory requirements, or court orders; (c) necessary to resolve disputes and enforce agreements; (d) necessary for legitimate business purposes, including fraud prevention and security; or (e) you have not requested deletion, subject to our legal obligations.

10.2 Account Deletion

When you delete your account, we will delete or anonymize your personal information, except where we are required to retain it for: (a) legal, regulatory, or compliance purposes; (b) legitimate business purposes, including fraud prevention; (c) dispute resolution or enforcement of agreements; or (d) other purposes permitted by applicable law.

10.3 Backup Systems

Some information may remain in backup systems, cached pages, or archived records for a limited period after account deletion. We will delete such information in accordance with our data retention policies and applicable law.

10.4 Public Content

Content you have posted publicly may remain visible to other users even after account deletion, and we may retain such content as necessary for the App's operation and other users' experience.

11. International Data Transfers and Cross-Border Data Flows

11.1 Data Transfer Locations

Your information may be transferred to, stored, and processed in countries other than your country of residence, including but not limited to the United States, where our servers and data centers are located. These countries may have different data protection laws than your country.

11.2 Consent to Transfer

By using the App, you consent to the transfer of your information to these countries. We take appropriate safeguards to protect your information in accordance with this Policy, regardless of where it is processed.

11.3 Legal Mechanisms for Transfer

If you are located in the European Economic Area ('EEA'), United Kingdom, or Switzerland, we rely on appropriate legal mechanisms to transfer your information, including but not limited to: (a) Standard Contractual Clauses approved by the European Commission; (b) adequacy decisions by the European Commission; (c) your explicit consent; or (d) other mechanisms recognized under applicable law.

11.4 Data Processing Agreements

We enter into data processing agreements with our service providers and partners to ensure that your information is protected in accordance with applicable data protection laws, regardless of where it is processed.

12. California Privacy Rights (CCPA)

12.1 CCPA Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act ('CCPA'), including:

  • Right to Know: Request disclosure of what personal information we collect, use, disclose, and sell (we do not sell personal information)
  • Right to Delete: Request deletion of your personal information
  • Right to Opt-Out: Opt out of the sale of personal information (we do not sell personal information)
  • Right to Non-Discrimination: Exercise your rights without discrimination or retaliation
  • Right to Correct: Request correction of inaccurate personal information

12.2 Exercising CCPA Rights

To exercise your California privacy rights, please contact us through the App's support features or the contact information provided in the App. We will verify your identity before processing your request. We will respond to your request within 45 days (or as otherwise required by law).

12.3 Information Collected

In the past 12 months, we have collected the categories of personal information described in Section 2 of this Policy, including: (a) identifiers; (b) personal information categories; (c) protected classification characteristics; (d) commercial information; (e) internet or electronic network activity; (f) geolocation data; (g) audio, electronic, visual, or similar information; and (h) inferences drawn from other personal information.

12.4 Information Disclosed

We have disclosed personal information to service providers and business partners as described in Section 4 of this Policy. We do not sell personal information to third parties for their marketing purposes.

12.5 Authorized Agents

You may designate an authorized agent to make requests on your behalf. We will require proof of authorization and verification of your identity before processing requests from authorized agents.

13. European Privacy Rights (GDPR)

13.1 GDPR Rights

If you are located in the European Economic Area ('EEA'), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation ('GDPR'), including:

  • Right of access to your personal data
  • Right to rectification of inaccurate data
  • Right to erasure ('right to be forgotten')
  • Right to restrict processing
  • Right to data portability
  • Right to object to processing
  • Right to withdraw consent
  • Right to lodge a complaint with a supervisory authority

13.2 Exercising GDPR Rights

To exercise your GDPR rights, please contact us through the App's support features or the contact information provided in the App. You also have the right to lodge a complaint with your local data protection authority if you believe we have violated your privacy rights.

13.3 Legal Basis for Processing

Our legal basis for processing your information is described in Section 3.7 of this Policy. We process your information based on: (a) performance of a contract; (b) legitimate interests; (c) consent; (d) legal obligations; (e) vital interests; or (f) public interest, as applicable.

13.4 Data Protection Officer

If you have questions or concerns about our data processing practices under GDPR, you may contact our Data Protection Officer (if designated) through the contact information provided in the App.

14. Third-Party Services, Integrations, and Links

14.1 Third-Party Services

The App may contain links to third-party websites, services, or applications, and may integrate with third-party services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies and terms of service.

14.2 Third-Party Services We Use

Third-party services we use include, but are not limited to:

  • Firebase (authentication, database, storage, analytics) - Google Privacy Policy
  • Google services (maps, analytics, cloud services) - Google Privacy Policy
  • Apple services (Sign In, App Store, payment processing) - Apple Privacy Policy
  • Payment processors (Stripe, PayPal, and others) - Their respective privacy policies
  • Social media platforms (when you link accounts) - Their respective privacy policies
  • Analytics providers (Google Analytics, Firebase Analytics, and others) - Their respective privacy policies
  • Email and notification services - Their respective privacy policies

14.3 Third-Party Data Collection

Third-party services may collect and use your information according to their own privacy policies and terms of service. We are not responsible for the data practices of third-party services. You should review the privacy policies of third-party services before using them through the App.

15. Marketing Communications and Advertising

15.1 Marketing Communications

We may send you marketing communications, including promotional emails, push notifications, and in-app messages, with your consent where required by applicable law. You can opt out of marketing communications at any time through: (a) your account settings; (b) the unsubscribe link in marketing emails; (c) your device notification settings; or (d) by contacting us.

15.2 Service Communications

You may not opt out of service-related communications, including: (a) account notifications; (b) security alerts; (c) important updates about the App; (d) changes to these Terms or this Policy; or (e) other communications necessary for the App's operation.

15.3 Advertising

We may use your information to provide personalized advertising and marketing. We may share information with advertising partners to deliver relevant ads, subject to your privacy settings and applicable law. You can control advertising preferences through your device settings and the App's privacy settings.

16. Changes to This Privacy Policy

16.1 Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other reasons. We will notify you of material changes by: (a) posting the updated Policy in the App with an updated 'Last Updated' date; (b) sending you a notification through the App or by email (for significant changes); or (c) other reasonable means.

16.2 Acceptance of Changes

Your continued use of the App after changes to this Policy constitutes acceptance of the updated Policy. If you do not agree to the updated Policy, you must stop using the App and delete your account. We encourage you to review this Policy periodically to stay informed about how we protect your information.

16.3 Material Changes

Material changes to this Policy may include, but are not limited to: (a) changes to how we collect, use, or share information; (b) changes to your rights or choices; (c) changes to our data security practices; or (d) other significant changes that affect your privacy.

17. Contact Us and Privacy Inquiries

17.1 Contact Information

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

  • The App's support features and in-app contact options
  • Email at the address provided in the App
  • Written correspondence to the address provided in the App

17.2 Response Time

We will respond to your inquiries within a reasonable timeframe and in accordance with applicable law. For privacy-related requests, we will respond within the timeframes required by applicable law (e.g., 30-45 days for CCPA requests, 30 days for GDPR requests).

17.3 Verification

We may require verification of your identity before processing certain privacy requests to protect your privacy and security. We will use reasonable methods to verify your identity, which may include requesting additional information or documentation.

18. Consent and Acknowledgment

By using the App, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, disclosure, transfer, storage, and processing of your information as described herein. You acknowledge that: (a) you have had the opportunity to review this Policy; (b) you understand your rights and choices regarding your information; (c) you consent to the data practices described in this Policy; and (d) you understand that your use of the App is subject to this Policy.

If you do not agree with this Policy, please do not use the App and must immediately delete your account, if any. Your use of the App constitutes your acceptance of this Policy and your agreement to be bound by it.

19. Additional State-Specific Privacy Rights

19.1 Nevada Privacy Rights

If you are a Nevada resident, you have the right to opt out of the sale of certain personal information. We do not sell personal information as defined under Nevada law, but you may contact us to exercise your rights.

19.2 Virginia Privacy Rights (VCDPA)

If you are a Virginia resident, you have rights under the Virginia Consumer Data Protection Act ('VCDPA'), including rights to access, delete, correct, and opt out of certain data processing. Please contact us to exercise your VCDPA rights.

19.3 Colorado Privacy Rights (CPA)

If you are a Colorado resident, you have rights under the Colorado Privacy Act ('CPA'), including rights to access, delete, correct, and opt out of certain data processing. Please contact us to exercise your CPA rights.

19.4 Connecticut Privacy Rights (CTDPA)

If you are a Connecticut resident, you have rights under the Connecticut Data Privacy Act ('CTDPA'), including rights to access, delete, correct, and opt out of certain data processing. Please contact us to exercise your CTDPA rights.

19.5 Other State Privacy Laws

Other states may have privacy laws that provide additional rights. We will comply with applicable state privacy laws and honor your rights under such laws. Please contact us if you have questions about your state-specific privacy rights.

20. Data Minimization and Purpose Limitation

20.1 Data Minimization

We collect and process only the information that is necessary for the purposes described in this Policy. We do not collect or process more information than is reasonably necessary to provide the App and its features.

20.2 Purpose Limitation

We use your information only for the purposes described in this Policy and for compatible purposes. We do not use your information for purposes that are incompatible with the purposes for which it was collected, unless we have your consent or are required by law.

21. Data Accuracy and Quality

We strive to maintain accurate and up-to-date information about you. You are responsible for ensuring that the information you provide is accurate, current, and complete. You can update your information through the App settings at any time. We are not responsible for inaccuracies in information you provide or for decisions made based on inaccurate information.

22. Special Categories of Personal Data

22.1 Sensitive Information

We may process special categories of personal data (sensitive personal information) in limited circumstances, such as: (a) information you explicitly provide; (b) information necessary for the App's functionality; or (c) information required by law. We process such information in accordance with applicable law and with appropriate safeguards.

22.2 Consent for Sensitive Data

Where required by applicable law, we will obtain your explicit consent before processing sensitive personal information. You can withdraw your consent at any time, subject to our legal obligations and the App's functionality.

23. Automated Decision-Making and Profiling

23.1 Automated Processing

We may use automated decision-making and profiling, including for: (a) NIL score calculations; (b) matching and recommendations; (c) fraud prevention; and (d) content personalization. You have the right to object to automated decision-making and to request human intervention, where applicable under law.

23.2 Algorithmic Transparency

While we use algorithms and automated systems, we do not make decisions that significantly affect you based solely on automated processing without human review, except where permitted by law or with your explicit consent.

24. Data Processing Records and Accountability

24.1 Record Keeping

We maintain records of our data processing activities as required by applicable law, including records of: (a) the purposes of processing; (b) categories of data subjects and personal data; (c) categories of recipients; (d) transfers to third countries; and (e) retention periods.

24.2 Accountability

We are committed to accountability and demonstrate compliance with applicable data protection laws through: (a) implementing appropriate technical and organizational measures; (b) maintaining documentation of our data processing activities; (c) conducting privacy impact assessments where appropriate; and (d) training our employees on data protection.

25. Privacy by Design and Default

We implement privacy by design and default principles, meaning we: (a) consider privacy at the design stage of our services; (b) implement privacy-friendly defaults; (c) minimize data collection and processing; (d) provide transparency about our data practices; and (e) give you control over your information.

26. Data Subject Access Requests and Response Procedures

26.1 Request Process

If you wish to exercise your privacy rights, you can submit a request through: (a) the App's support features; (b) email; or (c) written correspondence. We will acknowledge your request and respond within the timeframes required by applicable law.

26.2 Verification Requirements

We may require verification of your identity before processing requests to protect your privacy and security. Verification may include: (a) confirming your account information; (b) requesting additional identification; or (c) other reasonable verification methods.

26.3 Response Format

We will provide responses in a clear and understandable format. For data access requests, we will provide your information in a portable, machine-readable format where requested and feasible.

27. Data Protection Impact Assessments

We conduct data protection impact assessments ('DPIAs') for high-risk processing activities, as required by applicable law. DPIAs help us identify and mitigate privacy risks and ensure compliance with data protection laws.

28. Breach Notification Procedures

28.1 Breach Detection and Response

We have procedures in place to detect, investigate, and respond to data breaches. In the event of a data breach that may affect your personal information, we will: (a) investigate the breach promptly; (b) assess the risk and impact; (c) take steps to mitigate the breach; and (d) notify affected users and authorities as required by law.

28.2 Notification Timing

We will notify you of any material data breach without undue delay and in accordance with applicable law. Notifications will include: (a) a description of the breach; (b) the types of information affected; (c) the potential consequences; (d) the measures we are taking; and (e) steps you can take to protect yourself.

29. Third-Party Data Processors and Sub-Processors

29.1 Processor Agreements

We enter into data processing agreements with our third-party processors and sub-processors to ensure that your information is protected in accordance with applicable data protection laws. These agreements require processors to: (a) process data only as instructed; (b) implement appropriate security measures; (c) assist with data subject requests; and (d) comply with applicable data protection laws.

29.2 Processor List

A list of our key data processors is available upon request. We may update this list from time to time as we add or change processors.

30. Cross-Device Tracking and Linking

We may link your information across devices and platforms to provide a consistent experience and to improve our services. This may include linking your account information, usage data, and preferences across devices. You can control some aspects of cross-device tracking through your privacy settings.

31. Social Media Integration and Sharing

31.1 Social Media Linking

If you link your social media accounts to the App, we may access and collect information from those accounts in accordance with the permissions you grant and the privacy policies of those platforms. You can unlink your social media accounts at any time through the App settings.

31.2 Social Media Sharing

The App may include features that allow you to share content to social media platforms. When you use these features, your information may be shared with those platforms in accordance with their privacy policies. We are not responsible for the privacy practices of social media platforms.

32. Research and Analytics

32.1 Research Use

We may use your information for research and analytics purposes to improve our services, understand user behavior, and develop new features. We may share aggregated, anonymized data with researchers and partners for these purposes.

32.2 Anonymization

When using your information for research, we take steps to anonymize or de-identify the data to protect your privacy. Anonymized data cannot be used to identify you.

33. Employee and Contractor Access

Our employees and contractors may have access to your information as necessary to provide the App and its features. All employees and contractors are bound by confidentiality agreements and are trained on data protection and privacy. Access is limited to what is necessary for their job functions.

34. Legal Basis for Processing - Detailed Explanation

34.1 Contract Performance

We process your information to perform our contract with you, including: (a) providing the App and its features; (b) processing transactions and payments; (c) managing your account; and (d) providing customer support.

34.2 Legitimate Interests

We process your information based on our legitimate interests, including: (a) improving our services; (b) ensuring security and preventing fraud; (c) conducting business operations; (d) marketing and advertising (where permitted); and (e) legal compliance. We balance our legitimate interests against your privacy rights.

34.3 Consent

We process your information based on your consent for: (a) marketing communications; (b) certain data uses; (c) location services; (d) social media integration; and (e) other purposes where consent is required by law. You can withdraw your consent at any time.

34.4 Legal Obligations

We process your information to comply with legal obligations, including: (a) tax and accounting requirements; (b) law enforcement requests; (c) regulatory compliance; and (d) court orders.

35. Data Portability and Export

35.1 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format, and to transmit that information to another service provider, where technically feasible and as required by applicable law.

35.2 Export Functionality

You can export certain information through the App settings or by contacting us. We will provide your information in a portable format within a reasonable timeframe and in accordance with applicable law.

36. Right to Object and Opt-Out Rights

36.1 Objection Rights

You have the right to object to certain processing of your information, including: (a) processing based on legitimate interests; (b) direct marketing; (c) automated decision-making; and (d) profiling. We will honor your objections where required by applicable law.

36.2 Opt-Out Mechanisms

You can opt out of certain data uses through: (a) your account settings; (b) privacy settings; (c) notification preferences; (d) marketing communication preferences; and (e) by contacting us.

37. Supervisory Authority and Regulatory Compliance

37.1 Regulatory Oversight

We are subject to oversight by various regulatory authorities, including data protection authorities, consumer protection agencies, and other regulatory bodies. We cooperate with regulatory authorities and comply with their requirements.

37.2 Complaints

If you believe we have violated your privacy rights, you have the right to lodge a complaint with your local data protection authority or other relevant regulatory body. We will cooperate with any investigation and work to resolve any issues.

38. Business Continuity and Data Preservation

In the event of business continuity events, such as mergers, acquisitions, or business transfers, we will take steps to ensure that your information is protected and that your privacy rights are maintained. We will provide notice of such events as required by applicable law.

39. Special Considerations for Student-Athletes

39.1 NCAA Compliance

If you are a student-athlete, we may process your information in ways that comply with NCAA rules and regulations. We are not responsible for NCAA compliance, and you should consult with your school's compliance office regarding NCAA rules.

39.2 Educational Institution Access

Educational institutions may have access to certain information about their student-athletes as necessary for compliance and educational purposes, subject to applicable law and our agreements with such institutions.

40. Special Considerations for Business Users

40.1 Business Account Information

Business accounts may be subject to additional information collection and processing, including: (a) business verification information; (b) payment and billing information; (c) business analytics and insights; and (d) additional compliance information.

40.2 Business Data

Information about businesses, including business profiles, opportunities, and transactions, may be processed differently than individual user information, subject to applicable law and our agreements with business users.

41. Data Anonymization and Pseudonymization

We may anonymize or pseudonymize your information for various purposes, including research, analytics, and data sharing. Anonymized data cannot be used to identify you, and pseudonymized data uses identifiers that do not directly identify you.

42. Right to Restrict Processing

You have the right to request restriction of processing of your information in certain circumstances, including: (a) when you contest the accuracy of your information; (b) when processing is unlawful and you oppose erasure; (c) when we no longer need the information but you need it for legal claims; or (d) when you have objected to processing pending verification. We will honor restriction requests where required by applicable law.

43. Data Subject Rights Procedures and Timelines

43.1 Request Submission

You can submit data subject rights requests through: (a) the App's support features; (b) email; or (c) written correspondence. We will acknowledge your request promptly and respond within the timeframes required by applicable law (typically 30-45 days).

43.2 Extension of Timeframes

We may extend response timeframes by an additional period (typically 30-60 days) for complex requests, as permitted by applicable law. We will notify you of any extension and the reasons for it.

43.3 Fees

We generally do not charge fees for data subject rights requests. However, we may charge a reasonable fee for excessive or repetitive requests, as permitted by applicable law. We will notify you of any fees before processing your request.

44. Privacy Impact Assessments and Risk Management

We conduct privacy impact assessments for high-risk processing activities to identify and mitigate privacy risks. We implement risk management procedures to protect your information and ensure compliance with data protection laws.

45. Data Processing Records and Documentation

We maintain comprehensive records of our data processing activities, including: (a) purposes of processing; (b) categories of data subjects and personal data; (c) categories of recipients; (d) transfers to third countries; (e) retention periods; and (f) security measures. These records help us demonstrate compliance with applicable data protection laws.

46. Consent Management and Withdrawal

46.1 Consent Requirements

Where we rely on consent as a legal basis for processing, we will obtain your explicit, informed consent before processing your information. Consent must be freely given, specific, and unambiguous.

46.2 Withdrawal of Consent

You can withdraw your consent at any time by: (a) updating your privacy settings; (b) unsubscribing from communications; (c) disabling features that require consent; or (d) contacting us. Withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal.

47. Data Protection Officer and Privacy Contacts

47.1 Designated Privacy Contact

We have designated privacy contacts to handle privacy inquiries and data subject requests. You can contact our privacy team through the App's support features or the contact information provided in the App.

47.2 Data Protection Officer

If we are required to designate a Data Protection Officer ('DPO') under applicable law, we will do so and provide contact information for the DPO. The DPO is responsible for overseeing our data protection compliance and can be contacted regarding privacy matters.

48. Privacy by Default and User Control

We implement privacy by default principles, meaning we: (a) use privacy-friendly default settings; (b) minimize data collection by default; (c) provide clear privacy controls; and (d) give you meaningful choices about your information. You can adjust your privacy settings at any time through the App settings.

49. Data Retention Schedules and Deletion Procedures

49.1 Retention Schedules

We maintain data retention schedules that specify how long we retain different types of information. Retention periods are based on: (a) the purpose for which information was collected; (b) legal and regulatory requirements; (c) business needs; and (d) user requests.

49.2 Deletion Procedures

When information is deleted, we use secure deletion methods to ensure that information cannot be recovered. However, some information may remain in backup systems for a limited period, and we may retain information as required by law.

50. International Data Transfer Safeguards

50.1 Transfer Mechanisms

When transferring your information internationally, we use appropriate safeguards, including: (a) Standard Contractual Clauses; (b) adequacy decisions; (c) binding corporate rules; (d) certification schemes; or (e) other mechanisms recognized under applicable law.

50.2 Transfer Impact Assessments

We conduct transfer impact assessments to evaluate the risks of international data transfers and implement appropriate safeguards to protect your information.

51. Final Acknowledgment and Consent

BY USING THE APP, YOU ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY POLICY CAREFULLY, UNDERSTAND IT, AND CONSENT TO THE COLLECTION, USE, DISCLOSURE, TRANSFER, STORAGE, AND PROCESSING OF YOUR INFORMATION AS DESCRIBED HEREIN. YOU ACKNOWLEDGE THAT YOU HAVE HAD THE OPPORTUNITY TO REVIEW THIS POLICY AND UNDERSTAND YOUR RIGHTS AND CHOICES REGARDING YOUR INFORMATION.

IF YOU DO NOT AGREE WITH THIS POLICY, PLEASE DO NOT USE THE APP AND MUST IMMEDIATELY DELETE YOUR ACCOUNT, IF ANY. YOUR USE OF THE APP CONSTITUTES YOUR ACCEPTANCE OF THIS POLICY AND YOUR AGREEMENT TO BE BOUND BY IT.