PRIVACY POLICY

1. Information We Collect

RTFS may collect personal information that users provide directly to RTFS, including:

• name;
• email address;
• telephone number;
• home or permanent address;
• date of birth;
• account and login information;
• payment and transaction information;
• information relating to fantasy leagues, contests, entries, winnings, and account activity; and
• other information reasonably necessary to establish, maintain, or administer an RTFS account or provide the Services.

For public contests in which prizes are awarded, RTFS may also collect information necessary to verify a player's identity, age, eligibility, and physical location. Depending upon applicable requirements and the verification process, this information may include legal name, permanent address, date of birth, geolocation information, and partial or complete Social Security number.

RTFS may also collect information associated with use of the Services, including account activity, contest participation, transactions, device and connection information, IP addresses, and other information reasonably necessary to operate, secure, and administer the Services.

2. How We Use Personal Information

RTFS may use personal information to:

• establish, maintain, authenticate, and administer user accounts;
• provide RTFS websites, applications, contests, leagues, and other Services;
• determine eligibility for contests and prizes;
• verify identity, age, permanent address, and physical location;
• process entries, purchases, deposits, withdrawals, refunds, and prize payments;
• administer and score fantasy leagues and contests;
• provide customer service;
• maintain, troubleshoot, and improve the functionality and security of the Services;
• detect and prevent fraud, unauthorized account access, abuse, and violations of RTFS rules;
• maintain records required for business, security, accounting, tax, legal, and regulatory purposes;
• comply with applicable federal and state laws, regulations, regulatory requirements, court orders, and legal processes; and
• communicate with users regarding accounts, RTFS products and services, and promotions.

RTFS may use email addresses for promotional communications concerning RTFS products and services or promotions involving RTFS marketing partners. Users may opt out of promotional email communications using the opt-out functionality provided by RTFS.

Personal information will not be used for unauthorized solicitation.

3. Sharing and Disclosure of Personal Information

RTFS does not sell personal information to third parties.

RTFS may share limited personal information with third-party service providers when reasonably necessary to operate or provide the Services. These providers may include payment processors, identity and age verification providers, geolocation providers, financial institutions, tax service providers, software and technology providers, hosting providers, and other vendors providing services on behalf of RTFS.

For example, a user's name and email address may be provided to a software or technology provider when necessary for proper operation of an RTFS website or mobile application.

RTFS may disclose personal information when required or permitted by applicable law, regulation, legal process, court order, or an authorized governmental or regulatory authority.

Where applicable, account activity and winnings may be reported to state regulatory authorities, and winnings and associated taxpayer information may be reported to the Internal Revenue Service or other applicable taxing authorities.

RTFS does not authorize service providers receiving personal information from RTFS to use that information for their own unrelated marketing purposes.

4. Identity, Age, and Geolocation Verification

RTFS may collect and process information necessary to verify the identity, age, permanent address, eligibility, and physical location of participants in public fantasy contests.

RTFS may use third-party verification services that access public or private databases for these purposes. Players may be required to provide partial or complete Social Security numbers when necessary to complete identity verification.

Verification information may be used for identity, age, eligibility, and geolocation verification and associated fraud prevention, account security, regulatory compliance, recordkeeping, and legal obligations.

RTFS does not sell identity verification information or use it for unrelated marketing purposes.

5. Payment Information

RTFS may retain the last four digits of a user's credit or debit card number when necessary to identify transactions or process potential refunds.

RTFS does not retain full payment-card numbers, payment-card expiration dates, or card security codes (CVV). Full payment-card information is handled and retained by RTFS's third-party payment processing provider.

RTFS maintains payment and transaction records as necessary for accounting, fraud prevention, dispute resolution, tax, legal, and regulatory purposes.

6. Social Security Numbers and Tax Information

RTFS may collect a Social Security number when necessary to satisfy federal or state tax reporting requirements, identity verification requirements, or other applicable legal or regulatory obligations.

When tax reporting is required, this information may be used to prepare required tax documents and reports and may be provided to the Internal Revenue Service, applicable state taxing authorities, or other governmental or regulatory authorities as required by law.

RTFS does not use Social Security numbers for marketing purposes.

7. Children's Privacy and Age Restrictions

A person must be at least 14 years of age to establish an RTFS account.

Persons under 18 years of age are prohibited from participating in RTFS fantasy contests requiring an entry fee. Individual contests or jurisdictions may impose additional age restrictions as provided in the applicable contest rules.

RTFS may use third-party age and identity verification services to enforce these requirements.

8. Data Security

RTFS maintains administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, loss, destruction, or misuse.

Security protections are applied according to the nature and sensitivity of the information being protected. Access to sensitive personal information is restricted to personnel and authorized service providers requiring access for legitimate business, customer service, security, legal, or regulatory purposes.

RTFS uses encryption and other security controls for sensitive information as appropriate to its classification and maintains security controls for databases and database backups containing sensitive information.

No Internet-connected information system can be guaranteed to be completely secure. RTFS therefore cannot guarantee that unauthorized access, disclosure, or other security incidents will never occur.

9. Data Retention

RTFS maintains records in accordance with its established data-retention policies and applicable business, security, accounting, tax, legal, and regulatory requirements.

Active and inactive customer accounts are retained for a minimum of seven (7) years following the customer's last account activity. Any subsequent activity on the account resets the seven-year retention period.

RTFS retains the following records for a minimum of seven (7) years:

• customer play, entry, and winnings history;
• transaction records, including records of entry fees paid and winnings paid to players;
• season-long contest data; and
• daily fantasy sports ("DFS") contest data and results.

Other information, including identity verification, security, tax, accounting, and regulatory records, may be retained for the period required or permitted by applicable law, regulation, regulatory requirement, legitimate business requirement, or RTFS policy.

Information may be retained beyond a normally applicable retention period when it is subject to a legal hold, regulatory requirement, pending investigation, dispute, security incident, litigation, or other documented retention requirement.

10. Account Closure and Deletion Requests

Players may request that their RTFS account be permanently closed and may request deletion of personal information associated with their account.

Closing an account does not immediately eliminate RTFS's obligation to retain records. Information subject to the minimum seven-year retention periods described above will continue to be retained for the applicable retention period.

RTFS may also retain information when required or permitted for tax reporting, regulatory recordkeeping, fraud prevention, security, legal proceedings, disputes, investigations, or other applicable legal or regulatory requirements.

When a deletion request applies to personal information that RTFS is not required or permitted to retain, RTFS will delete or otherwise securely dispose of that information in accordance with its data security and retention policies.

11. Secure Data Destruction

When personal information reaches the end of its required retention period and is no longer required for a legitimate business, legal, regulatory, security, or other authorized purpose, RTFS will securely delete or destroy the information.

Electronic information maintained on active systems will be permanently deleted using methods appropriate for the applicable storage technology.

Information contained in backups will be removed through RTFS's normal backup expiration and rotation processes in accordance with applicable retention policies.

Before computers, servers, hard drives, solid-state drives, removable media, or other storage devices containing RTFS information are sold, recycled, discarded, returned to a vendor, or otherwise removed from RTFS control, RTFS will securely wipe the applicable storage media or physically destroy it. Where secure wiping cannot reasonably ensure that information is unrecoverable, the storage media will be physically destroyed.

Information subject to a legal hold, regulatory requirement, pending investigation, or other documented retention requirement will not be destroyed until the applicable hold or requirement has been released.

12. Promotional Communications

RTFS may communicate with users regarding RTFS products, services, contests, promotions, and promotions involving RTFS marketing partners.

Users may opt out of promotional email communications by using the unsubscribe or opt-out mechanism provided in the applicable communication.

Opting out of promotional communications does not prevent RTFS from sending non-promotional communications necessary to administer an account, transaction, contest, security matter, legal or regulatory requirement, or other aspect of the Services.

13. Cookies and Similar Technologies

RTFS websites and applications may use cookies and similar technologies necessary to operate the Services, maintain user sessions, authenticate users, maintain security, remember preferences, and provide website and application functionality.

RTFS may also use such technologies to understand use of the Services and improve their performance and functionality.

A user's browser or device may provide controls for managing cookies. Disabling certain cookies may prevent portions of the Services from functioning properly.

14. Legal and Regulatory Disclosures

RTFS may preserve, access, use, or disclose personal information when RTFS reasonably believes such action is necessary to:

• comply with applicable law or regulation;
• comply with legal process, court orders, or governmental or regulatory requests;
• enforce RTFS Terms of Service or contest rules;
• investigate suspected fraud, illegal activity, security incidents, or violations of RTFS policies;
• protect the rights, property, security, or safety of RTFS, its users, or others; or
• satisfy applicable licensing, regulatory, tax, or recordkeeping obligations.

15. Changes to this Privacy Policy

RTFS may update this Privacy Policy from time to time to reflect changes in its Services, business practices, security practices, legal requirements, or regulatory requirements.

When RTFS makes material changes to this Privacy Policy, RTFS will provide notice as appropriate under the circumstances and applicable law.

The effective date and most recent revision date will be displayed at the beginning of this Privacy Policy.

16. Contacting RTFS

Questions regarding this Privacy Policy, RTFS privacy practices, account closure, or requests concerning personal information may be submitted to RTFS through the customer support and contact methods provided on the RTFS website.