Privacy Policy

Introduction

This Privacy Policy describes the collection, use, disclosure, retention, and protection of personal information by VISBETS LLC ("VISBETS," "we," "our," or "us") in connection with the VISBETS mobile application ("App"). VISBETS is an analytics and prediction service for adult sports fans, focusing on sports analytics across soccer (including the Worlds Tournament) and the NBA — including statistics, model projections, odds, and data analysis. VISBETS does not operate as a sportsbook, does not take or process bets or wagers, does not hold user funds, and does not require or possess a gambling license.

Definitions

• Anonymized Data. Data that does not identify, and cannot reasonably be used to identify, any individual user
• Business Purpose. Use of Personal Information for the operation of the App and provision of services as described in this Policy
• CCPA/CPRA. California Consumer Privacy Act and California Privacy Rights Act, as amended and in effect
• Consumer Request. A request by a California resident to exercise rights laid out in the “U.S. and International Consumer Privacy Rights” section of this Policy
• Personal Information. Any information that identifies, relates to, describes, or could reasonably be linked with a particular consumer or household as defined under the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA")
• Sale. Disclosure or making available of Personal Information to a third party for monetary or other valuable consideration, as defined by CCPA/CPRA
• Sensitive Personal Information. Subset of Personal Information specified under CCPA/CPRA, including but not limited to: social security numbers, driver's license numbers, precise geolocation, financial account credentials, and certain protected classifications
• Service Provider. Entity that processes Personal Information on behalf of VisBets for a business purpose, subject to contractual limitations
• Sharing. Disclosure of Personal Information for purposes of cross-context behavioral advertising as defined by CCPA/CPRA
• Sub-Processors. Third-party service providers that process personal information on VISBETS's behalf, including but not limited to Supabase, RevenueCat, Railway, Apple, Amplitude, Sentry, TheOddsAPI, and API-Sports
• User. Any individual who installs, registers for, or uses the VISBETS App

Information Collection

VISBETS strictly adheres to data minimization and purpose limitation principles. We collect only the personal data adequate, relevant, and strictly necessary to provide our sports analytics services and do not process it for unrelated secondary purposes without your explicit consent.

Categories of Information Collected

Registration and Authentication Information: Email address and password (passwords are immediately hashed and never stored directly by VISBETS; authentication is provided by Supabase). We also offer third-party Single Sign-On (SSO) options, such as Google Sign-In via Google Cloud Platform. If you choose to authenticate via SSO, we receive your authentication token and basic profile information from that provider.

Subscription Status: Subscription activation, status, and expiry information (retrieved through RevenueCat and Apple In-App Purchase infrastructure); No payment card or billing information is ever accessed or processed by VISBETS; all payment interactions occur directly between the user, Apple, and RevenueCat.

Usage Analytics: Analytics on feature usage and app interactions (collected by Amplitude). These analytics are linked to your account identifier: they are pseudonymous — tied to an account ID rather than to your name — and they are never sold and never used for cross-app or cross-context behavioral advertising; Device type, operating system version, device identifiers strictly as permitted for analytics (no advertising or marketing IDs are used).

Device Information: Technical information about the app and device necessary for diagnostics and improvement (e.g., OS version, device model, error logs).

Information Not Collected

VISBETS does NOT collect or process:

• Geolocation or GPS information
• Contacts, photos, audio, video, or files stored on your device
• Social Security numbers, government-issued IDs, driver's license numbers, or biometric identifiers
• Credit card or banking information
• Purchase or transaction history unrelated to app subscriptions

Analytics Technologies

VISBETS and our sub-processors (such as Amplitude) use SDKs and mobile analytics to monitor app performance and understand how features are used. This is first-party analytics only: we do not use advertising identifiers (such as Apple's IDFA), we do not combine your information with third-party data for advertising purposes, we do not use it for cross-context behavioral advertising, and we do not share it with data brokers. Because VISBETS does not track you across other companies' apps and websites, the app does not request App Tracking Transparency permission. You may opt out of analytics at any time from the "Do Not Sell or Share" screen in your account settings.

Sources of Information

• User-provided Information: Information you provide directly to VISBETS when registering or interacting with the App
• Automatically Collected Information: Certain information is collected automatically by VISBETS Sub-Processors when you use the App
• Third-party Data: VISBETS retrieves sports statistics, player projections, odds, and media from third-party providers and public endpoints (including, but not limited to, TheOddsAPI, API-Sports, PrizePicks, Underdog Fantasy, and the NBA CDN) strictly to populate the App with informational content

Purposes of Collection and Use of Information

• To Provide and Operate the App: Including account creation, registration, authentication, subscription management, content delivery, and customer support
• To Improve and Analyze Services: Using usage analytics linked to your account identifier to enhance features, address bugs, and guide development
• To Manage Subscriptions: Including processing activations, renewals, and providing user support related to In-App Purchases as handled by Apple and RevenueCat
• To Protect Rights and Prevent Fraud: Including monitoring and investigation of suspicious or prohibited conduct, enforcing VISBETS's Terms of Service, and complying with applicable laws and regulations
• To Communicate with Users: Regarding account, subscription status, mandatory legal notices, policy changes, and support responses

VISBETS uses statistical models and analytics to provide game predictions and odds analysis for informational and entertainment purposes. However, we do not engage in automated decision-making or profiling that produces legal or similarly significant effects on our users.

Sub-Processors and Third-Party Recipients

Categories of Sub-Processors

• Supabase – authentication (email and password, hashed only)
• RevenueCat – subscription management and verification
• Apple – payment handling (In-App Purchase infrastructure)
• Railway – application hosting and infrastructure
• Amplitude – usage and diagnostics analytics (linked to your account identifier)
• TheOddsAPI, API-Sports – sports statistics and odds data provision
• Sentry – error monitoring, crash reporting, and application health metrics (may collect device state and IP addresses at the time of a crash)
• Expo / EAS – mobile framework and delivery of push notifications
• Google Cloud Platform – OAuth authentication

Data Sharing with Sub-Processors

VISBETS discloses user data to sub-processors only as necessary for the operation, improvement, and support of the App and only pursuant to written agreements requiring appropriate security and confidentiality.

No data is sold, licensed, or otherwise transferred for marketing, cross-context behavioral advertising, or unrelated purposes.

RevenueCat customer ID, product ID, will_renew, expires_at, and push tokens are collected for subscription management and delivery.

Disclosures Required by Law

VISBETS may disclose information where required by applicable law, subpoena, legal process, or government request, or where necessary to protect VISBETS's legal rights, public safety, or the App's integrity.

International Data Transfers

While VISBETS primarily operates within the United States, your information may be transferred to, processed, or stored in other jurisdictions. For users located outside the U.S., including the EEA or UK, we ensure that appropriate safeguards—such as Standard Contractual Clauses (SCCs)—are in place to protect your data during any cross-border transfers.

U.S. and International Consumer Privacy Rights

Depending on your jurisdiction of residence (e.g., Virginia, Colorado, the EEA, or the UK), you may possess additional statutory rights regarding your personal data, such as the right to access, correct, delete, or port your data, or the right to object to certain processing. You may exercise any applicable rights under your local laws by contacting us.

Applicability

If you are a California resident, you may have rights pursuant to the CCPA/CPRA.

Your Rights

• Right to know the categories and specific pieces of personal information collected about you, the sources, purposes, and third parties with whom it is shared
• Right to request deletion of your personal information, subject to statutory exceptions
• Right to correct inaccurate personal information
• Right to non-discriminatory treatment for exercising any privacy rights
• Right to direct VISBETS not to sell or share personal information (not applicable, as VISBETS does not sell or share information for marketing or commercial purposes)
• Right to designate an authorized agent to make requests on your behalf, subject to verification protocols

How to Exercise Your Rights

• Contact VISBETS at the email address provided in the "Contact Us" section below, or use any in-app method made available for managing privacy settings
• Provide sufficient information to verify your identity and authenticate your request (e.g., account email, recent access date)
• VISBETS will acknowledge receipt of your request within the period required by law and will respond substantively within applicable statutory time frames
• If you use an authorized agent, VISBETS may require proof of authority (such as written authorization signed by you or a power of attorney) and may take reasonable steps to verify your and your agent's identity
• Requests to delete information may be subject to denial where retention is necessary for business, legal, or security purposes as allowed by law

Data Retention and Deletion

Retention Policy

• VISBETS retains personal information only for as long as necessary to provide the App, fulfill the purposes described in this Policy, meet contractual and legal obligations, resolve disputes, enforce agreements, and as otherwise required by law
• Registration and subscription information is retained while you maintain an active account, plus a reasonable period thereafter for audit, dispute resolution, and legal compliance
• Usage analytics are linked to your account identifier and are retained while you maintain an active account, plus a reasonable period thereafter; they are deleted or de-identified when your account is deleted, subject to legal retention requirements
• Analytics data that has been aggregated or de-identified so that it no longer identifies, and cannot reasonably be used to identify, any individual user may be retained and used indefinitely

User-Requested Deletion

• Upon verified request, VISBETS will delete your personal information from its active records, subject to legal retention requirements
• Residual information may persist in backups or archives but will not be used except as required by law

Data Security

Safeguards

• VISBETS maintains commercially reasonable technical, physical, and administrative safeguards to protect the confidentiality, integrity, and security of personal information, including:
• Encryption of passwords via Supabase
• Use of secure transmission protocols (e.g., HTTPS)
• Limited access to personal data by authorization only
• Sub-processors are contractually required to maintain suitable security measures

No Guarantee

While VISBETS endeavors to maintain robust security, no internet, device, or mobile application transmission can be guaranteed 100% secure. You use the App at your own risk and are responsible for securing your device.

Data Breach Notification

In the event of a data breach that compromises your personal information, VISBETS will promptly notify affected users and relevant authorities in accordance with applicable federal and state laws, including the California Data Breach Notification Law. Notifications will outline the nature of the breach and the mitigation steps being taken.

Responsible Gambling and Age Restrictions

Age Limits

• The VISBETS App is strictly intended for individuals who are at least 21 years old, or the legal age of majority in their jurisdiction, whichever is higher. VISBETS does not knowingly allow individuals under the required age to create an account or use the App
• If you are not of legal age, you must not use this App. VISBETS reserves the right to terminate or restrict access for any user believed to be under the applicable minimum age

Responsible Gambling

• VISBETS does not facilitate, promote, or accept wagers or bets of any kind
• VISBETS is not responsible for any betting or gambling conducted by users on third-party platforms or services, and does not assume any liability for losses incurred in connection with use of VISBETS information
• VISBETS encourages all users to gamble responsibly, to not bet more than they can afford to lose, and to access support resources if gambling becomes problematic
• Information and links to responsible gambling resources are available in the App and on the VISBETS website

Warning and Legal Compliance

• It is your responsibility to comply with all applicable federal, state, and local laws regarding sports betting and the use of betting information
• VISBETS makes no representations or warranties regarding the legality of using the App's information or of engaging in gambling or sports betting activities in your jurisdiction

Legal Disclaimers

VISBETS Is Not a Sportsbook

• VISBETS provides information, analytics, odds, and predictions solely for educational, informational, and entertainment purposes. The App is not a gambling platform, sportsbook, or operator of any kind
• VISBETS does not accept or handle bets, process wagers, or hold or transfer user money
• VISBETS is not licensed to provide gambling services and does not require, nor claim to hold, any such license

Predictions and Data

• The App provides forecasts, analysis, odds, and data derived from historical and third-party sources
• VISBETS makes no guarantee as to the accuracy, completeness, currency, or reliability of any predictions or information provided
• All decisions based on information from the App are made at the user's sole discretion and risk

Third-Party Data

• Sports statistics, odds, and certain data provided in the App originate from third-party providers (including, but not limited to, TheOddsAPI and API-Sports)
• VISBETS disclaims all warranties and liability regarding the accuracy, timeliness, completeness, or reliability of third-party data, and is not responsible for errors, omissions, or delays in content supplied by such third parties

Third-Party Links

The App may contain links to or display odds from third-party services, such as sportsbooks, which are not governed by this Privacy Policy. VISBETS is not responsible for the data practices of third parties, and we encourage you to review their respective privacy policies before interacting with them.

Subscription Model, Auto-Renewal, and Payment Disclosures

Subscription Structure

• VISBETS is offered on a subscription basis, with payment handled exclusively through Apple In-App Purchases. All billing and payment processing are conducted by Apple; VISBETS does not access, receive, store, or process user payment card or banking information
• Subscription status is tracked and verified by RevenueCat, which receives information necessary to manage your subscription and provide service continuity

Auto-Renewal and Cancellation

• Unless explicitly canceled by the user in their Apple account settings prior to renewal, subscriptions will automatically renew at the prevailing rate
• Users are responsible for managing their own subscription preferences (including cancellations and renewals) through their Apple account interface
• VISBETS cannot process subscription cancellations or refunds directly; all subscription-related payment matters are governed by Apple and RevenueCat policies and terms

Account Termination and Suspension

• VISBETS reserves the right to suspend, restrict, or terminate any user account at its sole discretion, including for violation of this Privacy Policy or Terms of Service, suspected fraudulent or unlawful activity, or as required by law or court order
• Upon termination, user access may be immediately disabled, and data will be handled in accordance with the retention and deletion section of this Policy

Intellectual Property

Ownership

• All content, data, algorithms, analytics, designs, text, graphics, and intellectual property comprising or presented within the App (excluding third-party data subject to their respective licenses) are and remain the sole property of VISBETS LLC, protected by copyright, trademark, and applicable intellectual property laws
• No portion of the App, including predictive models, code, user interface, or data compilations, may be copied, distributed, modified, reverse-engineered, or otherwise exploited without express written consent of VISBETS

Limited License

• VISBETS grants users a limited, non-exclusive, non-transferable, revocable license to use the App strictly in accordance with these Terms and for lawful, personal, and non-commercial purposes only
• All rights not expressly granted herein are reserved by VISBETS

DMCA Agent Contact

To report alleged copyright infringement or submit DMCA notices, contact: privacy@visbets.com

Accessibility

Accessibility Policy

• VISBETS is committed to ensuring our Privacy Policy is accessible to all individuals, including those with disabilities. We strive to comply with recognized accessibility standards such as WCAG. This Privacy Policy is available in alternative formats upon request by contacting privacy@visbets.com
• VISBETS is committed to ensuring that all users, including those with disabilities, have meaningful access to the App and this Privacy Policy
• The Privacy Policy is provided in a format that is readable by commonly available assistive technologies and follows generally recognized industry standards (including relevant WCAG standards)
• Upon request, VISBETS will make this policy and related communications available in alternative formats reasonable for accommodation

Requesting Accommodations

• Users with disabilities may contact VISBETS using the contact information below to request accommodations or report accessibility barriers
• Each request will be documented, acknowledged within five (5) business days, and processed within a reasonable period
• User information submitted in connection with accommodation requests will be kept confidential as required by law

Notification of Material Changes

Updates

• This Privacy Policy is subject to updates. VISBETS maintains a log of previous versions of this policy, which are available to users upon request by contacting privacy@visbets.com
• Material changes affecting the collection, use, or sharing of personal information, user rights, or other substantive provisions will be communicated to users at least thirty (30) days prior to the effective date, via in-app notifications or by other reasonable means

Effective Date

• The effective date of the current version of this Policy is identified at the top of the document
• Users are encouraged to review the Policy periodically for any updates

Contact Us

Privacy Inquiries

To contact VISBETS regarding your privacy rights, submit privacy requests, accessibility accommodation requests, support needs, or questions regarding this Privacy Policy, you may use the following methods:

• Email: privacy@visbets.com
• In-app customer support or privacy settings (as available)
• Postal mail at VISBETS LLC, Attn: Privacy Compliance, 17015 Pine Ave, Los Gatos, CA 95032

Response to Inquiries

VISBETS will make reasonable efforts to respond substantively to all privacy-related requests within the periods required under applicable law.

Submitting a Consumer Request

To exercise your rights, submit a verifiable request using any of the following methods:

• Email: privacy@visbets.com
• In-App Form: Open the App settings, select "Privacy Request," and complete the secure request form
• Mail: VisBets LLC, Attn: Privacy, 17015 Pine Ave, Los Gatos, CA 95032

We require sufficient information to verify your identity before acting on your request (such as verifying the email account, in-app identification, or recent activity). Agents acting on your behalf must provide written authorization and sufficient evidence of your identity.

Miscellaneous

Governing Law

This Privacy Policy and any dispute or claim arising out of or relating to it shall be governed by the laws of the State of California, without regard to conflict of laws principles.

Severability

If any provision of this Privacy Policy is found by a court of competent jurisdiction to be invalid or unenforceable, such provision will be limited or eliminated to the minimum extent necessary so that the remainder of the Policy will otherwise remain in full force and effect.

Entire Agreement

This Privacy Policy constitutes the entire and exclusive agreement between VISBETS and users regarding personal information and supersedes any prior or contemporaneous agreements to the extent of any conflict.