Privacy Policy

1. Eligibility and Age Requirement

The Platform is intended only for individuals who are at least 18 years of age. We do not knowingly collect personal information from anyone under the age of 18. If you are under 18, you may not use the Platform or provide any personal information to us. If we learn that we have collected personal information from a person under 18, we will take steps to delete that information, subject to any legal retention obligations described in Section 7.

We are aware that younger athletes may wish to participate in the future. Any features permitting access by minors would be introduced separately, with appropriate guardian consent, controls, and compliance measures, and this Privacy Policy would be updated accordingly before any such features become available.

2. Information We Collect

We collect the following categories of personal information:

2.1 Information You Provide

• Account information, such as your name, email address, phone number, username, and password.
• Profile information, such as athlete or brand details, biographical information, and content you choose to share.
• Identity verification information, including government-issued identification documents and related data, which you submit and which is collected and processed by our third-party identity verification provider (see Section 4). This information may include biometric or facial-geometry data used to confirm that the identity document belongs to you.
• Communications you send to us, including support requests and correspondence.

2.2 Payment and Transaction Information

When you use the Platform’s payment features, payment information is collected and processed directly by our third-party payment processors, Stripe. Sportzap does not store your full payment card information or other sensitive payment credentials. We may receive limited transaction information (such as transaction amounts, dates, and payment status) from Stripe as necessary to operate the Platform and facilitate payments.

2.3 Information Collected Automatically

• Device and usage information, such as IP address, browser type, device identifiers, and pages or features accessed.
• Cookies and similar technologies, as described in Section 6.

3. How We Use Your Information

We use personal information to:

• Provide, operate, and maintain the Platform, including facilitating Zaps and ZapDeals.
• Facilitate the transmission of payment instructions to our payment processors.
• Verify your identity and comply with Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) obligations.
• Communicate with you about your account, transactions, and support requests.
• Detect, prevent, and address fraud, security issues, and prohibited activity.
• Comply with legal and regulatory obligations and enforce our Terms.

Artificial Intelligence. Sportzap does not use your User Content or personal information to train or develop general-purpose artificial intelligence or machine learning models except as disclosed in this Privacy Policy or with your consent. Sportzap may use automated tools, including AI-assisted tools, to operate, maintain, secure, improve, or support the Platform, provided such use is consistent with this Privacy Policy.

4. Third-Party Service Providers

We work with third-party service providers who process personal information on our behalf or in connection with the services they provide to you. These providers process your information in accordance with their own privacy policies, over which Sportzap has no control. The principal providers are:

These providers maintain independent privacy policies and practices, which govern how they process information collected through their services. While Sportzap carefully selects service providers, their handling of personal information is governed by their own policies.

As the Platform evolves, we may engage additional or alternative service providers, including processors for stablecoin or other payment methods. Where we do so, this Privacy Policy will be updated to reflect the applicable provider.

4A. Biometric Information

As part of our identity verification process, our third-party identity verification provider may collect and process biometric information, such as a scan of facial geometry derived from a photograph or short video, to verify your identity and help prevent fraud and impersonation.

Sportzap does not independently collect, store, or use biometric information for any purpose other than facilitating identity verification through its third-party provider. Any biometric information is processed in accordance with the provider's own privacy practices and applicable law. Where required by applicable law, your consent will be obtained before biometric information is collected or processed.

5. How We Share Your Information

We do not sell your personal information. We also do not share your personal information for cross-context behavioral advertising except as described in this Privacy Policy or as permitted by applicable law. We may share personal information in the following circumstances:

• With service providers, as described in Section 4, to operate the Platform.
• Between Users, to the extent necessary to facilitate a transaction (for example, information reasonably required to complete a Zap or ZapDeal between an athlete and another User). When a fan sends a Zap or a brand enters a ZapDeal, certain information reasonably necessary to complete and record that transaction (such as your name or display name and the transaction details) may be made available to the counterparty.
• Publicly, through athlete profiles. Athlete profiles are designed to be public. Information an athlete chooses to include in a profile, such as name or display name, biographical details, photographs, and linked social media accounts, may be visible to other Users and to the general public.
• For legal reasons, where we believe disclosure is required by applicable law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of Sportzap, our Users, or others.
• In a business transfer, in connection with a merger, acquisition, financing, or sale of assets, subject to standard confidentiality protections.

6. Cookies and Similar Technologies

We use cookies and similar technologies to operate and improve the Platform, remember your preferences, and understand how the Platform is used. You can manage your cookie preferences through your browser settings or any cookie controls we provide. Disabling certain cookies may affect the functionality of the Platform.

7. Data Retention

We retain personal information for as long as necessary to provide the Platform, fulfill the purposes described in this Privacy Policy, and comply with our legal and regulatory obligations.

Notwithstanding any account deletion or termination, Sportzap and its third-party service providers may retain certain identity verification and transaction records as required to comply with applicable legal and regulatory obligations, including KYC and AML recordkeeping requirements. These obligations may require retention of such records for a period of years following the closure or deletion of your account. When you delete your account, we will deactivate your access and remove or de-identify your profile information, except where retention is required by law or by the obligations of our payment and verification providers.

8. Data Security

We implement reasonable technical and organizational measures designed to protect personal information against unauthorized access, loss, or misuse. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security. No security measure is perfect or impenetrable. Sensitive payment and identity information is handled directly by our specialized third-party processors, which maintain their own security measures.

In the event of a data breach affecting your personal information, we will notify affected users and applicable regulators where, and within the timeframes, required by applicable law. If a breach occurs at one of our third-party service providers, we will coordinate with that provider regarding notification as appropriate.

9. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information, which may include the right to access, correct, delete, or restrict the processing of your information, and the right to data portability. To exercise these rights, contact us using the details in Section 12. We will respond in accordance with applicable law. Please note that certain information may be subject to the retention obligations described in Section 7 and may not be deleted upon request.

European Economic Area, United Kingdom, and Switzerland. For individuals in these regions, Sportzap acts as a controller of the personal information described in this Privacy Policy. We process personal information on the following legal bases: to perform our contract with you and provide the Platform; to comply with legal and regulatory obligations, including identity verification, KYC, and AML requirements; for our legitimate interests in operating, securing, and improving the Platform and preventing fraud, where not overridden by your rights; and, where required, on the basis of your consent, including for the processing of biometric data described in Section 4A. Where processing is based on consent, you may withdraw your consent at any time. You also have the right to lodge a complaint with your local data protection authority.

California and other U.S. states. Depending on your state of residence, you may have the right to know the categories and specific pieces of personal information we collect, the right to request deletion or correction, and the right to opt out of the “sale” or “sharing” of personal information as those terms are defined under applicable state law. As stated in Section 5, we do not sell your personal information. We will not discriminate against you for exercising any of these rights. You may use an authorized agent to submit a request on your behalf, subject to our verification of the agent’s authority. The categories of personal information we collect and the purposes for which we use them are described in Sections 2, 3, 4, and 4A.

10. International Data Transfers

Our service providers may be located in jurisdictions outside your country of residence, including the European Union (for example, our identity verification provider, UAB “iDenfy,” is based in Lithuania) and the United States. This means your personal information, including identity and biometric verification data, may be transferred to, stored in, and processed in countries whose data protection laws differ from those of your home jurisdiction. Where we transfer personal information of individuals in the European Economic Area, the United Kingdom, or Switzerland to a country that has not received an adequacy decision, we rely on appropriate safeguards as required by applicable law, such as the European Commission’s Standard Contractual Clauses or another lawful transfer mechanism. You may contact us for further information about the safeguards applicable to a particular transfer.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the “Last Updated” date above and, where appropriate, provide additional notice. Your continued use of the Platform after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. If required by applicable law, we will provide additional notice before material changes become effective.

12. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us at the support address provided on the Platform.