Privacy Policy

Version 1.0 | Effective Date: November 10, 2026 | Last Updated: November 10, 2026

This Privacy Policy explains how FreeGame360, LLC ("FreeGame360," "we," "us," or "our") collects, uses, discloses, sells, licenses, retains, and protects information about you when you use the FreeGame360 platform. FreeGame360, LLC is the company of record and the data controller responsible for all Personal Data described in this Privacy Policy.

FreeGame360, LLC is a separate company from FreeGame LLC (the athlete representation and marketing business) and FreeGame Ventures. This Privacy Policy covers only FreeGame360.

1. Scope and Who This Policy Covers

This Privacy Policy applies to all information collected through or in connection with the "Platform," which means, collectively and without limitation: the website located at www.fg-360.com and all related domains and subdomains; the FreeGame360 web and mobile applications; the FitScore, TotalFit, Explore Mode, fit-scoring, matching, benchmarking, and market-comparison features; all assessments, questionnaires, surveys, intake forms, reassessments, and self-evaluations; the FreeGame360 AI assistant and any other conversational, agentic, or automated feature; all education, content, and development programs; all application programming interfaces (APIs), integrations, data feeds, and connected-device features; all events, camps, combines, clinics, showcases, webinars, and pilots operated or co-operated by FreeGame360; and all emails, text messages, and other communications that link to this Privacy Policy.

This Privacy Policy covers all persons whose information we process, including: (a) athletes of any sport, level, or age permitted by our Terms of Service ("Athletes"); (b) parents and legal guardians of Athletes ("Parents"); (c) coaches, recruiters, scouts, athletic department staff, trainers, and other personnel of schools, colleges, universities, clubs, academies, teams, leagues, and other athletic organizations ("Programs" and "Program Users"); (d) visitors to our websites; (e) participants in research, pilots, and beta programs; and (f) any other person who contacts or interacts with us.

2. Key Definitions

The following terms have the meanings below wherever they appear in this Privacy Policy and our Terms of Service. Each definition is intended to be read as broadly as applicable law permits, and the words "including" and "such as" mean "including without limitation."

"Personal Data" means any 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, in any form or medium, whether collected from you, from a Parent, from a Program, from a third party, from public sources, from connected devices, or generated by the Platform. Personal Data includes Athlete Data, Sensitive Personal Data, Derived Data, and Inferences to the extent they remain linked or reasonably linkable to an individual.

"Athlete Data" means all Personal Data about an Athlete's athletic, academic, developmental, recruiting, commercial, and personal journey, including Profile Data, Performance Data, Academic Data, Recruiting Data, Preference Data, Assessment Data, Wellness Data, Commercial and NIL Data, Content, Outcome Data, and AI Interaction Data, each as described in Section 3.

"Sensitive Personal Data" means Personal Data that applicable law treats as sensitive or as consumer health data, including: information about physical or mental health, injuries, medical history, treatment, rehabilitation, medications, or health-related conditions; physiological or biometric measurements from wearables or other devices (such as heart rate, heart rate variability, sleep, recovery, or exertion) to the extent treated as health data; racial or ethnic origin; religious beliefs; sexual orientation; citizenship or immigration status; precise geolocation; government-issued identification numbers; account log-in credentials; and Personal Data of a known child under 13.

"Derived Data" means any data, score, rating, ranking, index, grade, label, tag, classification, benchmark, projection, prediction, recommendation, insight, report, model output, feature, embedding, weight, or other information that FreeGame360 creates, computes, generates, infers, or derives from Personal Data or other data, whether by human analysis, statistical methods, algorithms, machine learning, artificial intelligence, or any other method, including FitScores, TotalFit scores, fit and match results, development trajectories, and Predictive Outputs.

"Inferences" means Derived Data about an individual's preferences, characteristics, tendencies, predispositions, behavior, attitudes, abilities, aptitudes, potential, fit, readiness, or likely future outcomes.

"Predictive Analytics" means the use of Personal Data, De-identified Data, Aggregated Data, and Derived Data, alone or combined with data from other sources, to build, train, test, validate, calibrate, and operate statistical, algorithmic, machine-learning, and artificial-intelligence models that estimate, forecast, project, simulate, or predict outcomes, and the outputs of those models ("Predictive Outputs"). Examples include: athlete-program fit; likelihood of roster, playing-time, development, transfer, retention, graduation, or professional outcomes; performance progression curves; injury-risk or workload indicators (only with Wellness Consent); market value, compensation, and NIL comparables; academic and career pathway fit; and cohort benchmarks.

"De-identified Data" means data that cannot reasonably be used to infer information about, or otherwise be linked to, an identified or identifiable individual or a device linked to that individual, for which FreeGame360 (a) takes reasonable technical and organizational measures to ensure the data cannot be associated with an individual, (b) publicly commits to maintain and use the data only in de-identified form and not to attempt to re-identify it, except to test the effectiveness of our de-identification methods, and (c) contractually obligates every recipient to comply with the same commitments.

"Aggregated Data" means information that relates to a group or category of individuals, from which individual identities and individually linkable information have been removed, and that is not linked or reasonably linkable to any individual or device, such as statistics, averages, distributions, trends, and benchmarks across cohorts.

"Data Collective" means any consortium, cooperative, pool, marketplace, exchange, clearinghouse, research network, data trust, or other arrangement, whether operated by FreeGame360 or by third parties, through which data about athletes is contributed, combined, licensed, sold, exchanged, or made available to members, licensees, researchers, or customers, and "Data Collective Participants" means the operators, members, licensees, researchers, and customers of a Data Collective.

"Data Licensee" means any third party to whom FreeGame360 sells, licenses, or otherwise makes available data or data products for consideration, including Data Collective Participants, research institutions, Programs, leagues, governing bodies, sports-technology and analytics companies, media companies, and brands.

"Sell," "Sale," and "Sold" have the broadest meaning given under applicable law and include selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating Personal Data to a third party for monetary or other valuable consideration. "Share" includes disclosing Personal Data for cross-context behavioral advertising. "Targeted Advertising" means displaying advertisements selected based on Personal Data obtained from your activities over time across unaffiliated websites or applications.

"Process" or "Processing" means any operation performed on data, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation, alteration, enrichment, combination, retrieval, consultation, analysis, modeling, use, disclosure, transmission, dissemination, alignment, restriction, de-identification, aggregation, erasure, and destruction.

"Minor" means an individual under 18 years of age (or under the age of majority where the individual resides, if higher). "Child" means an individual under 13 years of age.

3. Information We Collect

We collect the categories of Personal Data described below. Some categories are required to create an account or use a feature; others are optional and are marked as optional in the Platform. Where a category requires your separate consent, we say so.

3.1 Information You or Your Parent Provide

• Identity and Account Data: legal name, preferred name, username, password (hashed), email address, telephone number, mailing address, city, state, country, date of birth or age range, graduation year or class year, NCAA ID, gender (optional), profile photo, and Parent name and contact information.
• Profile Data: sport(s), position(s), role, jersey number, handedness, current and past teams, clubs, high schools, colleges, academies, and leagues, level of play, division, conference, coaches, awards, honors, rankings, and biography.
• Performance Data: physical measurements and measurables (such as height, weight, wingspan, standing reach, vertical jump, speed, agility, strength, and combine or testing results); game, season, and career statistics; advanced metrics; skills evaluations; practice and training data; film, video, and highlight links; and self-reported and coach-reported performance evaluations.
• Academic Data: school, grade level, GPA, standardized test scores, course information, intended major or field of study, academic honors, eligibility and clearinghouse status, and transcripts or academic records you choose to upload. We do not request education records directly from a school without your (or your Parent's) authorization.
• Recruiting Data: schools and Programs of interest, offers, contacts, visits, communications with Programs, commitments, signings, transfer-portal status and history, walk-on or scholarship status, and recruiting timelines.
• Preference Data: your stated preferences, priorities, and importance weights, including geography, distance from home, school size, academic reputation, program culture, coaching style, style of play, offensive and defensive systems, playing-time expectations, development resources, facilities, NIL and commercial environment, cost, social environment, and career goals, and every change you make to those preferences over time.
• Assessment Data: all responses to FreeGame360 assessments, reassessments, surveys, questionnaires, and self-reflection tools, including questions about goals, motivations, work habits, competitiveness, coachability, leadership, communication style, resilience, decision-making, and personal values, and the scores and results generated from them.
• Commercial and NIL Data: name, image, and likeness activity; brand deals and partnership categories; compensation ranges you choose to provide; social media handles; follower counts, engagement rates, and audience metrics; and marketability information.
• Content: photos, videos, audio, documents, notes, journal entries, messages, posts, comments, and any other material you upload, submit, or create on the Platform ("User Content").
• AI Interaction Data: prompts, questions, messages, and files you submit to the FreeGame360 AI assistant or other automated features, and the responses generated.
• Wellness Data (Sensitive; optional; requires separate Wellness Consent, requested only when you first add Wellness Data or connect a device): injury history, injury status, rehabilitation, return-to-play status, general health and wellness self-reports, sleep, nutrition, stress, recovery, training load, and data from wearables or connected fitness devices.
• Communications and Support Data: communications with us, including customer support requests, chat transcripts, feedback, survey responses, and call recordings where you are notified.
• Payment and Transaction Data: subscription tier, purchase history, billing name and address, and payment confirmation. Payment card data is collected and processed directly by our payment processor (currently Stripe); FreeGame360 does not store full payment card numbers. If you receive payments from FreeGame360 (for example, under a separate Data Release and Usage Agreement), we collect the payout and tax information required by law through our payment and tax vendors.
• Program User Data: for coaches and Program personnel: name, title, institution, work contact information, sport, roster and program information you submit, evaluations and notes you enter about Athletes, and your search, filtering, and viewing activity on the Platform.

3.2 Information Collected Automatically

• Device and Technical Data: IP address, device identifiers, device type, operating system, browser type and version, language settings, time zone, and approximate (city-level) location derived from IP address.
• Usage and Interaction Data: pages, screens, and features viewed or used; clicks, taps, scrolls, and navigation paths; search terms and filters; time spent; profile views and who viewed them; changes to preferences and weights; feature adoption; session dates and times; referring and exit pages; and error and crash logs.
• Cookies and Similar Technologies: as described in Section 13.

3.3 Information From Other Sources

• Programs, Coaches, and Teams: rosters, statistics, evaluations, measurements, and other information that Programs or coaches submit about Athletes.
• Parents: information a Parent provides about an Athlete.
• Public and Third-Party Sources: publicly available information, including official athletic and conference statistics, rosters, schedules, results, recruiting rankings, transfer-portal listings, media reports, and public social media profiles and metrics; licensed data from sports-data, analytics, and recruiting-information providers; and coach, staff, program, and institutional background information.
• Connected Services: information from third-party services you choose to connect (such as wearables, video platforms, stat services, or social media accounts), according to your authorization and the settings of that service.
• Outcome Data: information about your later athletic, academic, and career outcomes, such as where you enrolled or signed, roster status, playing time, statistics, transfers, graduation, professional or international play, and post-playing career, collected from you, from public sources, and through follow-up surveys, including after you stop actively using the Platform, unless you opt out of Long-Term Journey Tracking in your Privacy & Consent settings.
• Derived Data and Inferences: Derived Data and Inferences we generate as described in Sections 2 and 7.

3.4 Information We Do Not Collect

FreeGame360 does not collect: Social Security numbers (except when required by law for tax reporting on payments to you, and then only through our tax vendor); driver's license, passport, or other government ID numbers (except through an identity-verification vendor when you request verification or when a Parent verifies their identity); biometric identifiers such as face geometry, fingerprints, or voiceprints; or precise geolocation.

4. How We Use Information

We Process Personal Data for the following purposes, each of which we consider compatible with the reasons we collect it:

• Provide the Platform: create and manage accounts; build and display your profile; calculate and display FitScores, TotalFit scores, and other matches, comparisons, and results; operate the AI assistant; deliver education and development content; process payments; and provide customer support.
• Personalize: tailor recommendations, content, programs, education modules, and insights to you, including based on your preferences, activity, and Inferences.
• Connect You With Programs: make your profile, data, and results visible to Programs according to your visibility settings (for Minors, only after a Parent verifies their identity and turns visibility on).
• Predictive Analytics and Research: conduct Predictive Analytics; analyze patterns and relationships among preferences, program attributes, development, and outcomes; conduct longitudinal and cohort studies; and create benchmarks, indices, rankings, and reports.
• Build and Improve Models and Products: build, train, fine-tune, test, validate, calibrate, monitor, and improve our algorithms, statistical models, machine-learning models, and artificial-intelligence models (including large language models and agentic systems), and develop new products, features, and services.
• Create De-identified and Aggregated Data: de-identify and aggregate Personal Data and use, commercialize, license, and sell the resulting De-identified Data and Aggregated Data for any lawful purpose, as described in Section 6.
• Data Collective and Data Licensing: for Athletes 18 and older who have not opted out, contribute, license, and Sell Personal Data to the Data Collective and Data Licensees, as described in Section 6.
• Communicate: send service, account, security, and transactional messages; send educational and marketing emails (you may unsubscribe at any time); and send text messages only with your separate SMS consent.
• Safety, Security, and Integrity: authenticate users; detect, prevent, and respond to fraud, abuse, security incidents, and violations of our Terms; and debug and repair systems.
• Legal and Compliance: comply with law, legal process, and regulatory requests; enforce our agreements; establish, exercise, or defend legal claims; and maintain consent and compliance records.
• Business Operations and Transactions: accounting, auditing, analytics, planning, investor and lender diligence (using De-identified or Aggregated Data wherever practical), and in connection with any merger, financing, acquisition, reorganization, or sale of all or part of our business or assets.
• Other Purposes With Consent: any other purpose disclosed to you at the time of collection or to which you consent.

We will not Process Personal Data for purposes that are materially different from, and incompatible with, those described above without first notifying you and, where required by law, obtaining your consent.

5. How We Disclose Information

We disclose Personal Data to the following categories of recipients:

• Programs and Program Users: according to your visibility settings. You control what Programs can see.
• Parents: Parents of Minor Athletes may access their Minor's account and data.
• Service Providers and Processors: vendors that Process data on our behalf and under our instructions, such as cloud hosting and database providers, application hosting, AI and large language model providers, payment processors, email and messaging providers, analytics providers, customer support tools, identity-verification and tax vendors, security vendors, and professional advisors. Our current sub-processor list is available on request at the contact information in Section 18.
• Data Collective Participants and Data Licensees: (a) De-identified Data and Aggregated Data, for any lawful purpose, subject to contractual no-re-identification obligations; and (b) identifiable Personal Data of Athletes 18 and older unless the Athlete has opted out of Sale, excluding all Sensitive Personal Data, as described in Section 6.
• Research Partners: universities, research institutions, and independent researchers, using De-identified or Aggregated Data, or identifiable data only with your consent.
• Connected Services: third-party services you direct us to connect or share with.
• Affiliates: FreeGame LLC and other entities under common ownership, only (a) to provide shared back-office, technical, legal, or administrative services under confidentiality obligations, or (b) as you expressly direct. Affiliates may not use FreeGame360 data to contact or solicit you for athlete representation unless you (or, for a Minor, a Parent) separately request it in your account.
• Legal and Safety: to comply with law, subpoenas, court orders, or lawful requests of public authorities; to protect the rights, property, or safety of FreeGame360, our users, or others; and to investigate fraud or security issues.
• Business Transfers: to an acquirer, successor, assignee, investor, or lender in connection with any merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of FreeGame360's business or assets, subject to that party's obligation to honor this Privacy Policy with respect to data collected under it.
• With Your Consent or At Your Direction: to any other party with your consent.

6. Data Collective, Data Licensing, and Sale of Data

• De-identified and Aggregated Data. FreeGame360 creates De-identified Data and Aggregated Data from Personal Data and may use, commercialize, license, Sell, and disclose that data to Data Collective Participants, Data Licensees, and others, for any lawful purpose, without further notice or compensation, to the extent permitted by law, except as limited below for Minors. De-identified and Aggregated Data are not Personal Data.
• Identifiable Personal Data: adults only, with a right to opt out. By accepting the Terms of Service, Athletes 18 and older authorize FreeGame360 to Sell or license their identifiable Personal Data to the Data Collective and Data Licensees. You may opt out at any time using the "Do Not Sell or Share My Personal Information" link in the Platform footer, in your Privacy & Consent settings, or by sending a Global Privacy Control signal. Opting out stops future Sales, and we will instruct recipients to stop further use where the law requires.
• Never sold: Minors' identifiable data. FreeGame360 does not Sell, and does not use for Targeted Advertising, identifiable Personal Data of any individual we know, or should know, is under 18. Minor Athlete data may be contributed to the Data Collective only as De-identified Data or Aggregated Data, and only if the Minor has separately agreed as described in Section 8. FreeGame360 also does not Sell identifiable Personal Data collected while an Athlete was a Minor, even after the Athlete turns 18.
• Never sold: Sensitive Personal Data. FreeGame360 does not Sell Sensitive Personal Data, including Wellness Data, in identifiable form, for any user of any age.
• Categories Sold (Athletes 18 and older who have not opted out): Identity and Account Data (limited to name, graduation year, and school or team), Profile Data, Performance Data, Academic Data, Recruiting Data, Preference Data, Assessment Data, Commercial and NIL Data, Outcome Data, and Derived Data and Inferences.
• Recipient Obligations. Every Data Licensee must agree in writing to use the data only for the licensed purposes, to protect it with reasonable security, to comply with applicable law, not to re-identify De-identified Data, and not to use Athlete Data to make unlawful decisions about any Athlete.
• Financial Incentives. FreeGame360 may offer payments, credits, discounts, premium access, or other benefits in exchange for contributing data, completing assessments, or granting optional permissions (for example, under a Data Release and Usage Agreement). The material terms of each offer will be presented before you participate. We calculate the value of your data based on a good-faith estimate of the expenses related to collecting and processing it and the value of the data products it supports. Participation is voluntary, and you may withdraw at any time.

7. Artificial Intelligence, Predictive Analytics, and Profiling

• How we use AI. FreeGame360 uses algorithms, machine learning, and artificial intelligence, including large language models provided by third-party vendors, to generate FitScores, matches, benchmarks, Predictive Outputs, and AI assistant responses.
• How our algorithms show information and content. The only thing FreeGame360 ranks is the list of college Programs shown to each Athlete. Programs are ranked by how well they match the Athlete's own ranked priorities for athletic fit, academic fit, and Program fit, and are filtered only by gender (men's or women's game) and, if the Athlete sets one, a maximum distance. AI-generated insights explain results but do not affect the ranking. FreeGame360 does not use a content feed, advertising, or engagement-based ranking. Minors' results are ranked the same way.
• Training models. FreeGame360 uses De-identified Data and Aggregated Data, and Personal Data (unless you opt out of research use of your identifiable data in your Privacy & Consent settings; for Minors, only if the Minor separately agrees, as described in Section 8), to build, train, and fine-tune our own models, which may include large language models.
• Profiling. We engage in profiling (automated Processing to evaluate, analyze, or predict aspects of a person, such as fit, preferences, performance, development, and potential). FreeGame360 does not itself make decisions based solely on automated Processing that produce legal or similarly significant effects (such as admission, scholarship, roster, employment, or financial decisions). Programs and other users make their own decisions.
• Scores are not guarantees. FitScores, Predictive Outputs, and AI responses are estimates based on available data. They can be incomplete or wrong. They are not guarantees of recruitment, admission, scholarship, eligibility, roster status, playing time, compensation, or any outcome.
• Your profiling rights. You may opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. Where applicable law provides (including Minnesota), you may question the result of profiling, be told the reasons for it, review the Personal Data used, and, if that data was inaccurate, have it corrected and the result reevaluated.

8. Minors and Parental Consent

• Children under 13. The Platform is not directed to Children under 13, and no one under 13 may create an account. If we learn we have collected Personal Data from a Child under 13 without verifiable parental consent, we will delete it. Parents who believe this has occurred should contact us at legal@fg-360.com.
• Minors who are at least 13 years old but under 18 years old. Minors may use the Platform only with the involvement and consent of a Parent. A Parent must review and accept the Terms of Service and this Privacy Policy on the Minor's behalf by checking the acceptance box on the verification page linked in the email FreeGame360 sends to the Parent, and the Parent may make or change the Minor's privacy choices in the Minor's Privacy & Consent settings, through the link FreeGame360 emails to the Parent, or by emailing legal@fg-360.com. A Parent may review, correct, download, or delete the Minor's data and change or withdraw any consent at any time, including through the link FreeGame360 emails to the Parent or by emailing legal@fg-360.com. Until a Parent verifies, a Minor’s account and the information the Minor enters are kept private, are not visible to Programs, and are used only to run the Minor’s account. If a Parent does not verify within 14 days after sign-up, we delete the account and its Personal Data.
• Heightened protections for Minors. For users we know, or should know, are under 18, FreeGame360: does not Sell identifiable Personal Data; does not engage in Targeted Advertising; does not collect precise geolocation; turns off profile visibility to Programs by default until a Parent verifies their identity and turns it on; and limits Processing to what is reasonably necessary for the Platform and the purposes consented to; and does not use a Minor's Personal Data for research, Predictive Analytics, or building or training models, for Long-Term Journey Tracking, for marketing email, or to create De-identified Data or Aggregated Data for licensing, sale, or a Data Collective, unless the Minor separately agrees in the Minor's Privacy & Consent settings. Declining does not affect the Minor's use of the Platform, and the Minor may withdraw agreement at any time as easily as it was given.
• Turning 18. When a Minor Athlete turns 18, the Athlete will be asked to accept the Terms of Service and this Privacy Policy in the Athlete's own name. Until the Athlete accepts, the Athlete's data continues to be treated as a Minor's data and is not Sold. Personal Data collected while the Athlete was a Minor is not Sold, even after the Athlete accepts.
• Recruiting rules. Athletes, Parents, and Programs are responsible for complying with the recruiting, eligibility, and NIL rules that apply to them (including NCAA, NAIA, NJCAA, conference, state high school association, and state law rules).

9. Sensitive Personal Data and Consumer Health Data

We collect Wellness Data and any other Sensitive Personal Data only with your separate, affirmative Wellness Consent (or a Parent's consent for a Minor), which we request in a separate prompt when you first add Wellness Data or connect a device, and never as part of accepting the Terms of Service, and only for the purposes disclosed at the time of consent: to personalize development insights, to track readiness and workload, and, where you consent, to support Predictive Analytics in de-identified form. We do not Sell Sensitive Personal Data. We do not disclose identifiable Wellness Data to Programs unless you turn on that specific sharing setting. You may withdraw Wellness Consent at any time, after which we will stop collecting and delete identifiable Wellness Data, except as required by law.

Consumer Health Data Notice (Washington, Nevada, and similar laws). The categories of consumer health data we collect are listed under Wellness Data in Section 3.1. We collect it from you, your Parent, and connected devices you authorize. We use it for the purposes above. We share it only with service providers that Process it on our behalf and, if you turn on that setting, with Programs you choose. You may access, delete, and withdraw consent for your consumer health data by contacting us as described in Section 18.

10. Retention

We retain Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, including:

• Account, Profile, and Athlete Data: for the life of your account and up to 24 months after your account is closed or becomes inactive, unless you request deletion sooner. If you delete your account, we remove you from Program results right away and delete your Personal Data within 30 days, except the records described below. A Parent may delete a Minor's account. Deleted data may remain in backup copies for up to 30 days before it is overwritten.
• Inactive accounts: accounts with no log-in for 24 months may be closed and their Personal Data deleted or de-identified after notice.
• Wellness Data: until you withdraw Wellness Consent or close your account, whichever occurs first.
• Consent, transaction, tax, and compliance records: up to 7 years, or longer if required by law.
• De-identified and Aggregated Data: indefinitely, because it is not Personal Data.
• Derived Data and trained models: models trained using data before a deletion or withdrawal request may be retained. Your identifiable Derived Data and Inferences are deleted with your account.

11. Security

We use reasonable administrative, technical, and physical safeguards designed to protect Personal Data.

No system is completely secure. If a data breach affecting your Personal Data occurs, we will notify you and regulators as required by law.

12. Your Rights and Choices

Depending on where you live, you (or your Parent or authorized agent) may:

• Access and Know: confirm whether we Process your Personal Data, access it, and learn the categories of data, sources, purposes, and recipients, including a list of the specific third parties to whom we have Sold Personal Data where the law provides that right.
• Correct: correct inaccurate Personal Data.
• Delete: delete Personal Data, subject to legal exceptions.
• Portability: obtain a copy of your Personal Data in a portable, readily usable format.
• Opt Out: opt out of the Sale of Personal Data, Targeted Advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects. You can opt out of Sale at any time using the "Do Not Sell or Share My Personal Information" link in the Platform footer.
• Withdraw Consent: withdraw any consent at any time, without affecting the lawfulness of Processing before withdrawal.
• Question Profiling: exercise the profiling rights in Section 7.
• Appeal: appeal our decision on any request by replying to our decision or emailing us with the subject "Privacy Appeal." If your appeal is denied, you may contact your state Attorney General.
• Non-Discrimination: we will not discriminate against you for exercising your rights. Some features that depend on a specific type of data may not work without it.

How to exercise your rights. Use the privacy settings in your account, or email legal@fg-360.com with the subject "Privacy Request," or write to FreeGame360, LLC, Attn: Privacy, 8400 Normandale Lake Blvd., Suite 920, Bloomington, MN 55437. We will verify your identity before completing a request and respond within 45 days (extendable as permitted by law). We do not charge a fee unless requests are manifestly unfounded or excessive. Authorized agents must provide written proof of authorization.

Universal opt-out signals. We honor the Global Privacy Control (GPC) and similar legally recognized opt-out preference signals as a request to opt out of Sale and Targeted Advertising for that browser or device.

13. Cookies and Similar Technologies

We use cookies, pixels, local storage, SDKs, and similar technologies ("Cookies") that are:

• Strictly Necessary: required to operate the Platform, keep you logged in, and secure your account.
• Functional: remember your settings and preferences.
• Analytics: help us understand how the Platform is used and improve it. Analytics data may be linked to your account to improve your experience and our models.

FreeGame360 does not use Targeted Advertising cookies for users under 18 and does not currently use Targeted Advertising cookies for any user. If that changes for adult users, we will update this Privacy Policy and provide an opt-out as required by law. You can control non-essential Cookies through the cookie settings on the Platform and through your browser.

14. Communications

You may unsubscribe from marketing emails at any time using the link in the email. Service and account messages cannot be turned off while you have an account. We send marketing or informational text messages only with your separate express written consent; message and data rates may apply; reply STOP to opt out or HELP for help. Consent to text messages is not a condition of any purchase or use of the Platform.

15. International Users

FreeGame360 is based in the United States, and Personal Data is stored and Processed in the United States. If you access the Platform from outside the United States, you understand that your data will be transferred to, stored in, and Processed in the United States, where data protection laws may differ from those in your country.

16. Third-Party Services and Links

The Platform may link to or integrate with third-party websites and services that we do not control. Their privacy practices are governed by their own policies. FreeGame360 is not responsible for their practices and cannot guarantee that other users, Programs, or third parties will comply with applicable laws and regulations.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version with a new "Last Updated" date. If we make a material change, we will notify you by email or in the Platform at least 30 days before it takes effect. We will not use Personal Data collected before a material change in a materially different way, or Sell it where we previously did not, without your affirmative consent.

18. Contact Us